The instructions to Form ADV-W contain additional information and examples to assist you in responding to Item 8. NOTE: Section 204 of the Advisers Act, or similar state law, requires you to preserve your books and records after you have withdrawn from registration.

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16 Feb 2018 All rights reserved. You also could use the “placeholder” guidance issued by the SEC last month (IA Watch, Aug. 14,. 2017) . While Form ADV, Part 1 Item 9 (custody) wasn't among revisions to the form this year, the SEC's.31 Jan 2001 If you report on your annual updating amendment that you have assets under management of less than $25 million and you are not otherwise eligible to register with the SEC, you must withdraw from SEC registration within 180 days after the end of your fiscal year by filing Form ADV-W. You should consult state law in the 31 Oct 2017 New Form ADV Item 9 Custody Guidance Took Effect on October 1, 2017 Lexington Compliance and RIA in a Box LLC are not law firms, To satisfy the requirements of Form ADV while using umbrella registration the filing adviser must sign, file, and update as required, a single Form ADV (Parts 1 and 2) that relates to, and includes all information concerning, the filing adviser and each relying adviser (e.g., disciplinary information and ownership 27 Sep 2017 A high-level overview of certain key changes and practical guidance regarding As with the rest of Form ADV Part 1A, this information will be available to . If a custodian holds at least 10% of an adviser's total SMA regulatory assets . is the obligation to pay or the right to receive a given amount of money Form ADV - Part 2A - Firm Brochure Item 15: Custody . of an event is the date that the tinal order, judgment, or decree was entered, or the date that any rights. 18 Feb 2019 (2) If you are using this Form ADV to register more than one investment . Part 1A Instruction 2 provides information to help you determine ment advisers that have custody of client funds or securities to undergo an annual surprise examination The Form ADV-E filing and the surprise examination report or statement filed by the ac- secure link to the Form ADV-E Surprise Examination Filing Website along with instructions for uploading All rights reserved. 6 Sep 2017 The Form ADV amendments follow other SEC rulemaking . clients use the same custodian in the event a concern is . Instructions to Form ADV to help an adviser .. the right to receive a given amount of money accruing.