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Custody

SQN Capital relied on the Audited Financials Alternative to attempt to comply with the custody rule during the relevant period but failed to do so
TSP Capital will pay a $60K penalty under settlement agreement
TSP Capital also failed to comply with the requirement that every investment adviser registered with the Commission adopt and implement written P&Ps
RCW exclusive analysis of Form ADV data
No enforcement if financials can't be “distributed in time under certain unforeseeable circumstances”
The Division would not recommend enforcement action for distributing late a pool's audited financial statements due to certain unforeseeable circumstances
The FAQ slaps five conditions on the use of this regulatory relief
The SEC would not recommend enforcement action to the Commission under Advisers Act rule 206(4)-2 if an adviser does not maintain the certificates with a ...
If “logistical disruptions” caused by the coronavirus prevent the accountant from doing the surprise exam, it can be delayed
If the accountant failed to do the exam within the deadline due to the "logistical disruptions" caused by COVID-19, the filing deadline can be extended
The Form ADV FAQ addresses temporary teleworking
The SEC considers a "firm’s business continuity plan in response to circumstances related to coronavirus disease 2019"
OCIE examiners “expected us to have records of all of these reviews” for first party SLOAs
Another custody sweep exam letter from a 2020 OCIE exam of an advisory firm
Check out the degree of OCIE's interest in custody
A peer shares the firm's custody checklist
The custody rule requires advisers to hire only auditors who are both PCAOB registered and subject to board inspection. But the PCAOB hasn’t yet adopted ...
This letter extends that no-action relief until the date that a PCAOB-adopted permanent program begins
A guide to help you comply with the custody rule
The outcome of each case will speak to the Commission’s interpretation of how serious such offenses are and what punishment fits these violations
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