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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
Former SEC official and now Proskauer Partner Robert Plaze permits RCW to share his guide to the Advisers' Act custody rule.
A New York investment adviser didn’t hire a public accountant to audit its subsidiary’s private fund and now its bank account is $250,000 lighter, the ...
In July 2016, GIG’s Chief Compliance Officer identified the omission of parties from the Application and the resulting non-compliance with the Co-Invest Order and informed ...
ED Capital also failed to comply with the requirement that every investment adviser registered with the Commission adopt and implement written policies and procedures reasonably ...
This is a copy of an adviser's OCIE document request letter from a 2018 exam that focused on custody.
Questions have swirled in the industry around the application of the federal securities laws and FINRA rules regarding the custody of digital asset securities. In ...

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