Aug. 29, 2023
RIA's using qualified custodians (TD Ameritrade, Schwab, etc.) are by definition having the custodians & custody accounts. RIA's should only use qualified custodians anyway to safeguard clients monies. Alternative investments should be exempt as many are held at the sponsor and then just replicated on the custodian's website/statement. There are few custodians that will actually hold Alternative investments, making it impossible for the RIA to assume custody. Directing trades inside client accounts is not custody.