When does the Custody Rule apply?

• The adviser have possession of client funds or securities (for any length of time).

• The adviser withdraw funds or securities on behalf of the client.

• The adviser deduct certain fees on behalf of the client.

• The adviser have legal ownership of, or access to, client funds or securities.

• A related person have custody over the client’s funds or securities.

What are the Custody Rule Requirements?

• Use a Qualified Custodian to maintain client assets.

• Segregate Client Funds: Keep each client’s assets in separate, clearly identified accounts.

• Notify Clients Promptly: Provide written notice when opening new custodial accounts, including custodian details and fund handling procedures.

• Ensure Statement Delivery: Confirm custodians send quarterly account statements directly to clients, detailing holdings and all transactions.