1) Blair, Bohlé & Whitsitt PLLC (BBW) provides surprise custody examinations to ensure compliance with new SEC requirements for Registered Investment Advisers that have custody of client assets. 2) The SEC's new rules expand reporting requirements and require an annual surprise examination by an independent accounting firm for any RIA with custody. 3) BBW will conduct examinations to verify account integrity by confirming account balances and transactions with custodians and clients.

1. ASSURANCE & ADVISORY Offering Critical Services that Meet
Surprise New Mandatory SEC Requirements
Custody Blair, Bohlé & Whitsitt PLLC examinations ensure
compliance by verifying account integrity.
Examinations The SEC's new provisions for asset custody expand the reporting requirements
for Registered Investment Advisers (RIAs). Each RIA with custody is required to
have an annual surprise custody examination conducted by an independent
Locally entrenched. certified public accounting firm. By requiring an official examination with "another
Professionally connected. set of eyes," RIAs can ensure better protection for their clients against
Uniquely qualified. misappropriation.
Guidance from the SEC on the New Rule:
BBW's Assurance Group provides Rule 206(4)-2(a) generally requires that client funds and securities of which an
quality-centric services that drive investment adviser has custody under the rule be verified by actual examination
business value for clients. at least once during each calendar year by an independent public accountant,
through a written agreement, between the investment adviser and the accountant,
By coupling extensive experience at a time that is chosen by the accountant without prior notice or announcement
with keen regulatory insight, to the investment adviser.
BBW provides accounting, audit,
and related services to BBW is an Independent and Insightful Accounting Partner.
businesses, governmental
entities and not-for-profit BBW will produce verification through:
organizations.
- Confirmation with the qualified custodian(s) of client funds and securities as
of the date of the examination and that the client's funds and securities are held
in either aseparate account under the client's name or in accounts under the
name of the investment adviser as agent or trustee for clients.
- Confirmation with the client of funds and securities held in the account as of
the date of the examination and contributions and withdrawals of funds and
securities to and from the account since the date of the last examination; where
confirmation replies are not received, the accountant should perform alternative
procedures.
- Reconciliation of confirmations received and other evidence obtained to the
investment adviser's records.
BBW's examination report includes an opinion as to whether, with respect to the rules
Partner Contact: under the Act, the investment adviser was in compliance, in all material respects, with
paragraph (a)(1) of Rule 206(4)-2 as of the examination date and had been complying
Steven J. Johnston with Rule 204-2(b) during the period since the prior examination date.
10815 Sikes Place, Suite 100
Charlotte, NC 28277
704-841-9814 Direct As an independent resource, BBW is required to notify the Commission within one busi-
ness day of any finding of any material discrepancy during the course of examinations.
704-841-9800 Main
704-841-9802 Fax The Securities & Exchange Commission (SEC) approved amendments to Rule 206(4)-2 (the "Custody
Rule") under the Investment Advisors Act of 1940 effective May 12, 2010. All surprise custody examina-
sjohnston@bbwpllc.com tions must be initiated before December 31, 2010.
www.bbwpllc.com Why Choose BBW?
BBW provides high value for client investments by fitting services to each
individual need. The firm's strong core competencies are supplemented by
a network of professional partner resources focused on quality, value-based
services. Through its network, clients can fulfill unique and specialized needs
through partners whose personal touch and attention to detail mirror that of BBW.
Integrity Attention to Detail Personal Service
Accountants first. Advisors foremost.