Custody Crackdown

Earlier this year, the SEC’s Division of Examinations published its priorities for 2022. There was a significant focus area on private funds. In particular, looking at: “compliance with the Advisers Act Custody Rule, including the “audit exception” to the surprise examination requirement and related reporting and updating of Form ADV regarding the audit and auditors … Read more »

The One with the Missing Audits

The basic premise of the Custody Rule is that registered investment advisers who have custody ofclient assets must implement specific safekeeping requirements to prevent loss, misuse, or misappropriation of those assets. (Rule 206(4)-2) For non-fund managers, there is a surprise exam requirement. For fund managers, the usual route is through audited financial statements. The Custody … Read more »