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National Exam Program Risk Alert: Significant …

1 By the Office of Compliance Inspections and Examinations1 Volume III, Issue 1 March 4, 2013 Significant Deficiencies Involving Adviser Custody and Safety of Client Assets One of the most critical rules under the Investment Advisers Act of 1940 ( Advisers Act ) is the custody rule,2 which is designed to protect advisory clients from the misuse or misappropriation of their funds and securities. Yet, the SEC s National Examination Program ( NEP ) has observed widespread and varied non-compliance with elements of the custody The NEP reviewed recent examinations that contained Significant deficiencies. Approximately one-third of them (over 140) included custody-related issues. In this Risk alert , the NEP staff shares the custody deficiencies observed, which we hope will assist investment advisers in complying with the custody rule.

1 By the Office of Compliance Inspections and Examinations. 1. Volume III, Issue 1 March 4, 2013 . Significant Deficiencies Involving Adviser Custody and

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