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Series 63: Regulation of Investment Advisers
Series 63 practice questionmediumSurprise exam edge cases

Which of the following advisers is LEAST likely to be required to undergo a surprise custody examination?

  1. AAn adviser who acts as a general partner of a pooled investment vehicle and deducts fees directly from the pool
  2. BAn adviser who serves as trustee to client accounts and holds funds in trust
  3. CAn adviser who only has authority to transfer client funds between accounts owned by the same client at different institutions✓ Correct answer
  4. DAn adviser who holds client stock certificates in a fireproof firm vault
Explanation

Why CAn 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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