Custody

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 ...