Surprise Custody Examinations


BBD's Investment Management Group To Be Acquired By Cohen & Company

We are pleased to announce the exciting news that our firm’s Investment Management Group will be acquired by Cohen & Company.

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Are You In Compliance With the SEC's Custody Rule?

Amendments to Rule 206(4)-2 of the Investment Advisers Act of 1940, the Custody Rule, adopted in 2010, were designed to provide expanded safeguards for clients of investment advisers.  Among these amendments to the Custody Rule is a provision that requires advisors to undergo annual surprise examinations when they are deemed to have custody of client funds or securities. The surprise examination must be conducted by an accounting firm registered with, and subject to examination by, the Public Company Accounting Oversight Board and must take place annually.

Despite many years of implementation, the amendments, including the surprise exam requirement, continue to raise questions and cause confusion for investment advisors.  

The Investment Management Group at BBD has performed many surprise custody examinations under these rules of the Investment Advisers Act of 1940 as well as similar examinations under Rule 206(4) of the Investment Advisers Act of 1940 and Rules 17f-1 and 17f-2 of the Investment Company Act of 1940. We have the experience and expertise to help you comply with your requirements.

Do you have questions about the Custody Rule?

Reach out. We'd love to speak with you!

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What Our Clients Are Saying

The BBD client experience is not just a promise in a proposal.

At BBD, we survey our clients regularly.  Monitoring and measuring the value of the BBD client experience on a consistent basis helps us to make improvements that have immediate impact.

The results of our surveys confirm that our clients value collaboration and partnership as much as we do, and that we are delivering on our commitment.

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Setting the PACE
For the Client Experience

Our values drive everything we do at BBD and differentiate us in the commoditized world of audit and tax services.  BBD's professionals are passionate about the distinct industries we serve; authentic in our relationships and communication with our clients; and collaborative in navigating our clients' challenges.  Our commitment to living these BBD core values enables us to deliver an exceptional client experience. We're setting the PACE for client experience quality.