Does your federally registered investment adviser firm have authority to initiate first-party transfers between the client’s accounts at different qualified custodians?
If so, your investment adviser firm should ensure that it meets the requirements to avoid custody as outlined in Question II.4 of the U.S. Securities and Exchange Commission’s “Staff Responses to Questions About the Custody Rule”. In order to document that your clients’ written instructions authorizing your investment adviser firm to initiate first-party transfers between different qualified custodians, RIA Compliance Consultants has prepared a sample form entitled “Custody – SLOA for First-Party Transfers Between Different Qualified Custodians – Spreadsheet Documenting Requirements”.
This sample spreadsheet for documenting first party transfers for custody purposes is available here to the annual compliance program clients of RIA Compliance Consultants. Other investment advisers can purchase the sample spreadsheet on an a la carte basis here. If you have any questions about this sample form or need assistance with custody, please contact RIA Compliance Consultants.