Objectives of the Presentation:
- Rule 206(4)-2
- Custody Defined
- Frequently Asked Questions
- We have Custody, Now What?
- Custody Fees
- Client Communication
- Internal Forensic Testing
- External Forensic Testing
Why Should you Attend?
There have been significant deficiencies over the years since the Custody Rule was amended, including a 2017 SEC No Action letter and revision to the FAQs on Custody. Advisers should understand the rule and how to effectively manage and oversee the policies and procedures surrounding it in order to properly secure their clients' assets and to avoid significant regulatory enforcement and penalties. A firm can have custody and not be aware that they do, if they have not properly tested their procedures to the detail of the full custody rule.
Coulter Strategic Services
Lisa M. Marsden, IACCP, is the president and founder of Coulter Strategic Services. Coulter Strategic Services provides financial advisors and consulting firms with compliance and project management services. Prior to that, Ms. Marsden was the chief operating officer/chief compliance officer of Financial Trust Asset Management, Boca Raton, Florida. She has been in the financial services industry for over 25 years. Ms. Marsden has a broad array of talent, knowledge and an entrepreneurial approach in the area of regulatory compliance and business operations.
Ms. Marsden has a degree in computer programming from Keiser University, and holds the Investment Advisor Certified Compliance Professional Designation and Claritas ® Investment Certificate. She was the chief compliance officer/chief technology officer at Steinberg Global Asset Management, Boca Raton Florida and also held positions in the banking trust industry at Midlantic National Bank and Trust, Comerica Bank & Trust and Barnett Bank Asset Management.
Ms. Marsden leads two extremely intelligent groups of local compliance and IT professionals with the goal to help educate themselves, their firms and each other in the area of cyber security and compliance regulation as it pertains to the financial area. She serves on the executive committee of the Financial Planners Association of Greater Fort Lauderdale, and has moderated a cyber-security panel consisting of a Certified Ethical Hacker and Securities and Exchange Commission Examiner for the FPA of Greater Fort Lauderdale's annual conference, conducted training sessions on the financial regulations regarding cyber security.
Audit Manager ,
Cohen Fund Audit Services
Focuses on audit and tax matters exclusively for the investment industry. Cohen Fund Audit Services spend 100% of their time training for and educating themselves on issues you may encounter, immersing themselves into industry trends, and developing strategies for current clients that may one day be adapted to help you. Working in your world day-in and day-out provides you with an incredibly efficient team and stellar client service.
Since joining the firm in 2007, Stacey has specialized in private company attest services and now exclusively focuses on the investment company industry, focusing on hedge funds and investment advisor audits. She is well-versed in accounting and financial reporting issues related to investment advisors and her clients look to her as an advisor on issues affecting their businesses. Furthermore, Stacey is involved in our surprise custody examination team to make sure Advisors are in compliance with the amended custody rule. Stacey is actively involved with staff scheduling and development as well as recruiting efforts for the Firm. Stacey attended Hiram College where she received her Bachelor of Science in Accounting and Financial Management. Additionally, she attended Bowling Green State University for her Masters in Accountancy. She is a member of the Ohio Society of Certified Public Accountants (OSCPA) and the American Institute of Certified Public Accountants (AICPA).