The complexity of the SEC’s Custody Rule is not to be underestimated. Custody issues remain among the most common deficiencies cited during SEC exams, and even firms with strong compliance programs have had challenges interpreting and applying the different rule elements, No-Action letters, FAQs and Investment Management Guidance Updates. Based on our experience in the field, CSS has created a unique offering to help you better understand the Custody Rule and how it applies to your business – the CSS Custody Toolkit.
Our Custody Toolkit will help you understand and document compliance with the key elements of the Custody Rule; identify accounts over which your firm has custody; identify available exceptions to certain requirements of the Rule based on industry guidance; manage a list of accounts to provide to an accountant for a surprise examination; and evidence your analysis for determining the information in Item 9 of your Form ADV Annual Updating.
The Toolkit includes:
- A robust, interactive Custody Questionnaire
- A Form ADV Worksheet template
- Aggregated library with links and references to underlying regulatory material
- And more
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