Custody: Critical Tips to Comprehend the Complex Rule and Avoid Non-Compliance
May 19, 2015
Webinar
Make no mistake: the SEC is continuing to test for compliance with the custody rule and still seeing issues of non-compliance.
The price for non-compliance can be high as CCOs have been charged with custody rule violations. Enforcement has homed in on CCOs whose firms never filed independent audit reports, didn’t arrange for a surprise exam or were even late in sending out audited financial statements. SEC Enforcement Deputy Director Stephanie Avakian has stated that custody rule violations will be a focus area in 2015.
Dechert partner Michael Sherman will participate on a panel that will discuss the following topics:
- How best to handle your Form ADV, Part 1A, Item 9 disclosures
- A rundown on the rule’s major responsibilities for advisers
- Details on the common mistakes that firms make with the custody rule
- Specifics on how the topic of custody comes up during SEC exams
- Insight on when you must choose between a surprise exam and an accountant’s report
- Testing ideas to gauge your firm’s custody compliance
- What the Form ADV-E is and why it’s so important
- How one adviser was granted relief to skip certain custody rule requirements
- Why the number of IAs reporting that they or a related person has custody is on the rise
