WARNING!! You THINK you don’t have Custody, but…

IM Guidance Update February 2017 Inadvertent Custody: Advisory Contract versus Custodial Contract Authority   The U.S. Securities and Exchange Commission’s Division of Investment Management recently released guidance to alert investment advisers that they “may inadvertently have custody of client funds … Read More ›

Custody No-Action Letter

    In the No-action letter, the SEC clarifies that the Commission believes that a letter of instruction or other similar asset transfer authorization arrangement established by a client and submitted by an investment adviser to the qualified custodian would … Read More ›

OCIE’s Top 5 RIA Deficiency Letter Topics

The Five Most Frequent Compliance Topics Identified in OCIE Examinations of Investment Advisers   Compliance Rule Rule 206(4)-7 makes it unlawful for an adviser to provide investment advice unless it (1) adopts and implements written policies and procedures reasonably designed … Read More ›