ACS' Compliance Cast

Scott reviews custody requirements in the order that they are covered in the 2024 Custody Review Checklist, which should help you complete your custody review.  Listen along while you review and complete your Custody Review Checklist. 

Scott discusses the importance of and, generally, the "how to" of the self-directed Advisory Fee Billing Practices Review.

Scott discusses due diligence generally and then walks through two tools (checklists) to help advisers conduct due diligence on vendors/service providers.

Scott walks through the 2023 Custody Review Checklist and describes constructive custody as it relates to Direct Fee Deduction and Standing Letters of Authorization.

Scott discusses Investment Adviser Representative Continuing Education Requirements including a rundown of states that have adopted of the rule (as of May 2023), the requirements of the Model Rule that the states are either adopting or working from, how to track your CE through FinPro, and how to get a FinPro account.

Lori provides a brief description/explanation of the Best Execution Review along with some of the background as to why it's necessary.

In this episode, Scott and Lori discuss the changes made to the compliance manual. Policies and procedures for the DOL's PTE 2020-02, the SEC's advertising rule, and other updates are covered.  

Scott and Lori introduce and explain a new flow chart for advisers to use as a tool to determine if their communication is marketing under the new rule, what is impermissible under the new Marketing Rule, and what sorts of information specific kinds of marketing must disclose.  Additionally, the tool includes templated sample disclosures to help advisers craft disclosures for their own marketing content based upon the particular information it contains.  Finally, Lori and Scott briefly discuss the new SEC alert related to the Marketing Rule and the information they have about its developing adoption in the States.

Scott describes and discusses the upcoming Custody Review for the ACS Lite Services' clients and goes through the review question by question addressing the potential questions and insights for each.

In this episode, Scott talks about the Custody Review for 2022, including the basic mechanics like who's getting what and what to do with it as well as a question-by-question discussion of the 2022 Review Checklist with analyses of Custody principles generally.  After listening to this episode, you should know what you need to do for the Custody Review, how you need to do it, and even why you need to do it.