During this webinar, one of our consultants will provide a general overview of the custody requirements under the Investment Advisers Act of 1940 Rule 206(4)-2 Custody of Funds or Securities of Clients by Investment Advisers. The primary focus of the webinar will be discussing “first-party” versus “third-party” disbursements/transfers in light of a February 2017 SEC no-action letter discussing custody; the SEC’s updated FAQs on this topic; and guidance provided by one of the major account custodians for registered investment advisers. Our consultant will provide you with tips for complying with the custody requirements of Rule 206(4)-2 and tips for avoiding custody inadvertent custody situations should your firm choose to not have custody of its client’s assets.
Date Recorded: October 26, 2017
Time: 73 minutes
If this product involves the purchase of a recorded webinar on a la cart basis (not part of an annual compliance program subscription), the purchaser will be redirected to access the recording of this webinar immediately from RIA Compliance Consultant’s KnowledgeBase after the purchase transaction is completed. For detailed instructions on how to access the KnowledgeBase, please refer to the following webpage: KnowledgeBase Instructions
If the individual intending to make a purchase is affiliated with a firm which has an active engagement with RIA Compliance Consultants for an annual compliance program (“ACP”), certain sample forms are available as part of ACP depending upon the package and do not need to be purchased separately. Please check the description of the sample form as to whether such form is included in your ACP package. If a sample form is included as part of your firm’s current ACP package and your firm (via the individual making payments in our system) has designated you as a team member in our Knowledge Base, please log into our Knowledge Base at https://www.ria-compliance-consultants.com/my-account/ to download such sample form. For detailed instructions on how to access the KnowledgeBase, please refer to the following webpage: KnowledgeBase Instructions
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Although the sponsor of this presentation, RIA Compliance Consultants, Inc. (“Sponsor”), is an affiliate of a law firm and Sponsor may have an individual on its staff that is also licensed as an attorney providing legal services in a completely separate capacity, Sponsor is not a law firm and does not provide legal services or legal advice. A consulting relationship with Sponsor does not provide the same protections as an attorney-client relationship.
This presentation is offered for educational purposes only and should not be considered an engagement with Presenter or Sponsor. This presentation should not be considered a comprehensive review or analysis of the topics discussed today. These materials are not a substitute for consulting with an attorney or compliance consultant in a one-on-one context whereby all the facts of your situation can be considered in their entirety.
Despite efforts to be accurate and current, this presentation may contain out-of-date information. Additionally, Presenter and Sponsor will not be under an obligation to advise you of any subsequent changes.
Information provided during this presentation is provided “as is” without warranty of any kind, either express or implied, including, without limitation, warranties and merchantability, fitness for a particular purpose, or non-infringement. Presenter and Sponsor assume no liability or responsibility for any errors or omissions in the content of the presentation.
Information provide during this presentation relates solely to the Investment Advisers Act of 1940 and the rules thereunder and, at times, we may reference similar state securities rules and regulations specific to registration as an investment adviser. Certain circumstances or arrangements you may have may warrant you to consider other regulations that may apply including, but not limited to: the Investment Company Act of 1940; the Securities Act of 1933; the Securities Exchange Act of 1934; ERISA and other Department of Labor regulations; federal or state laws and regulations and self-regulatory (e.g., FINRA) rules for broker-dealers and registered representatives/securities agents of broker-dealers; and state insurance rules and regulations. The Sponsor of this presentation does not provide any advice or consulting services outside the scope of the Investment Advisers Act of 1940 or similar investment adviser state securities rules and regulations. If you need advice regarding any other rules or regulations, the Sponsor recommends that you consult with an attorney or consultant that specializes in those specific rules or regulations.
There is no guarantee or promise that concepts, opinions and/or recommendations discussed will be favorably received by any particular court, arbitration panel or securities regulator or result in a certain outcome.
To the extent that you provide RCC with your email address, it will be added to RCC’s electronic newsletter mailing list regarding compliance issues for investment advisers. You may opt out at any time by calling RCC at 877-345-4034 or clicking at any time the “unsubscribe” link on the electronic newsletter.
Communication with today’s webinar presenter is not protected by attorney-client privilege. Please keep questions during this seminar in a hypothetical form. This seminar session and/or the presentation materials may be recorded, copied and/or shared with third parties and/or posted to our public website.
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