Surprise! What You May Not Know About the SEC's Custody Rule:  Jim Kaiser Authors Article For the Investment Adviser Association Newsletter

Posted by James Kaiser on Aug 13, 2018 6:27:00 PM

Investment advisers deemed to have custody of client funds or securities:  Is your accounting firm both registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board?  In certain situations, it's an important question.  Jim Kaiser explores this and other questions about the SEC's Custody Rule in a recent issue of the Investment Adviser Association newsletter.

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We're Just Back From The Investment Adviser Association 2018 Compliance Conference. Here's What You Need To Know Now.

Posted by Jesse LaGrossa on Apr 6, 2018 3:38:29 PM

BBD recently attended the Investment Adviser Association Compliance Conference, which was held last month in Washington, DC.  Among the hot topics covered were developments related to GIPS® Performance Verification and the SEC's Custody Rule.

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Treatment of Organization and Offering Costs For New Open-End Funds

Posted by admin on Apr 15, 2014 6:42:01 PM

Through our interaction with various clients, it has become clear there is much uncertainty with respect to the identification and treatment of organization and offering costs as they relate to a newly established open-ended mutual fund. In hopes of providing clarification on this matter, we have illustrated the accounting treatment of both types of costs in several different scenarios through which they may apply.

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Adviser Custody Rule Update- What You Need to Know About the SEC's Recent Risk Alert

Posted by admin on Apr 1, 2013 7:01:48 PM

It has been more than two years since the Securities and Exchange Commission (“SEC”) adopted amendments to Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Custody Rule”). While the initial response to the amendments from advisors and broker-dealers was mixed (See our previous post Initial Response to the Revised Custody Rule), it is imperative for advisors to ensure they are in compliance. On March 4, 2013, the SEC issued a Risk Alert and Investor Bulletin regarding the Adviser Custody Rule. The alert was issued in response to recent SEC examinations conducted as part of a National Examination Program that uncovered custody-related issues in around one-third of the advisors examined.

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Investment Management Group Partner Jim Kaiser Participates in Webinar on Current Valuation Issues Regarding Third-Party Pricing Vendors

Posted by admin on Apr 4, 2012 10:21:00 AM

Jim Kaiser, a partner in BBD's Investment Management Group, recently recorded a Webinar with Kristin McCann, Compliance Officer for Gemini Fund Services, LLC, discussing the use of a third-party pricing vendor and why we all need to become more of a valuation expert. Jim and Kristin offer valuable insight in the Webinar to both fund management and fund boards.

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SEC Takes Aim at Money Market Funds: Understanding Potential Regulations

Posted by Investment Management Group on Feb 28, 2012 3:33:10 PM

Money Market Funds currently comprise approximately $2.7 trillion in assets and are one of the most highly regulated forms of investment companies. Now the SEC is proposing reforms aimed at diminishing the perceived risk of investing in Money Market Funds. But these reforms may disrupt the business of investment advisors – both those advising Money Market Funds and those investing their assets in Money Market Funds.

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Recent Changes to Rule 2a-7 for Money Market Funds

Posted by Investment Management Group on Jul 21, 2011 8:17:57 PM

Last year, the Securities and Exchange Commission ( "SEC") implemented amendments to Rule 2a-7 compliance procedures for money market funds. The amendments are meant to provide better protection for money market fund investors.

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Initial Response to the Revised Custody Rule

Posted by Investment Management Group on Jul 21, 2011 7:50:27 PM

Effective March 12, 2010, the Securities and Exchange Commission (“SEC”) adopted amendments to Rule 206(4)-2 of the Investment Advisors Act of 1940 (the “Custody Rule”). These amendments are designed to provide additional safeguards when a registered advisor is deemed to have custody of client funds or securities by requiring the advisor to undergo an annual surprise examination by an independent public accountant who is subject to regular inspection by the Public Company Accounting Oversight Board. The annual surprise examination procedures are designed to verify that client funds and securities, of which an investment advisor has custody, are held by a qualified custodian and either in a separate account for each client or under the advisor’s name as agent or trustee for the client.

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