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Custody Rule Surprise Examinations

Simplifying Custody Rule Compliance

Sometimes, regulatory compliance is simpler than you thought.

The amendments to SEC Rule 206(4)-2 under the Investment Advisers Act of 1940 require investment advisers that have custody of client funds or securities to undergo an annual surprise examination by an independent public accounting firm that is a member of the Public Company Accounting Oversight Board (PCAOB).

From the time this amendment to the custody rule was issued in 2010, Fischer Cunnane worked closely with regulatory authorities to thoroughly understand its implications for RIAs. As a result, we have developed an intuitive, cost-effective approach for performing surprise examinations quickly and with minimal intrusion on your operations.

Because the custody rule allows certain exemptions, many RIAs are not sure whether they need to comply. Not only can Fischer Cunnane guide you through the process of making that determination, we also have experience working with the SEC to steer RIAs into compliance with the custody rule.

A member of the PCAOB since its inception, Fischer Cunnane is proud of our history of deficiency-free ratings. To view our most recent report, visit and click “registered firms.”

If you are searching for a PCAOB-registered accounting firm to conduct your surprise examination, call Rick Stiebritz at 610.431.1003 for a confidential discussion or email