If you are a registered investment adviser who – directly or indirectly – has authority to obtain possession of client funds or securities (“custody”), the SEC has increased your compliance burden beginning March 12, 2010.
It is now harder for registered advisers to avoid being deemed to have custody of advisory assets controlled by affiliated companies or funds.
Registered advisers with custody must, with several exceptions, begin having surprise annual audits of the custody assets before year-end.
