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GAO Report: Requirements and Costs Associated with the Investment Advisers Custody Rule
U.S. Government Accountability Office [GAO] Link to more items from this source
July 11, 2013
32 pages. "SEC provided an exception from the surprise examination requirement to, among others, advisers deemed to have custody solely because of their use of related but 'operationally independent' custodians.... To be considered operationally independent, an adviser and its related custodian must not be under common supervision, not share premises, and meet other conditions. About 2 percent of the SEC-registered advisers qualify for this exception for at least some of their clients. If the exception were eliminated, the cost of the surprise examination would vary across the advisers because the factors that affect examination cost vary widely across the advisers." [GAO-13-569, published Jul. 8, 2013, released Jul. 8, 2013]

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