Series 63 practice questionmediumSurprise exam edge cases
Which of the following advisers is LEAST likely to be required to undergo a surprise custody examination?
- AAn adviser who acts as a general partner of a pooled investment vehicle and deducts fees directly from the pool
- BAn adviser who serves as trustee to client accounts and holds funds in trust
- CAn adviser who only has authority to transfer client funds between accounts owned by the same client at different institutions✓ Correct answer
- DAn adviser who holds client stock certificates in a fireproof firm vault
Explanation
Why C — An adviser who only has authority to transfer client funds between accounts owned by the same client at different institutions
Moving funds solely between a client’s own accounts is not considered custody requiring a surprise exam, while the other scenarios do involve custody per NASAA Model Rule IA Custody.
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