RIA Compliance Consultants has prepared a new sample form, Custody – Best Practices for Supervising Bill Pay Services.
This is a sample checklist which provides an investment adviser firm with some best practices for supervising and/or mitigating the risks associated with providing bill pay services to clients.
Under no circumstances should this list of best practices be considered a recommendation that an investment adviser firm should offer a bill pay service. RIA Compliance Consultant, Inc. believes that operating a bill pay services pose a significant risk to an investment adviser firm. In other words, there’s a possibility that an employee or investment adviser representative could commit fraud and misappropriate a client’s assets through a bill pay service, which could lead to civil liability or regulatory enforcement action against the firm depending upon the facts and circumstances. Supervision of bill pay service against fraud or misappropriation is very challenging. This checklist should not be considered an exhaustive list of available techniques. There are no guarantees that these best practices will be effective, and this checklist does not create any type of safe harbor.
This sample checklist is included with Platinum & Titanium Packages through our Knowledge Base at https://www.ria-compliance-consultants.com/knowledge-base/custody-best-practices-for-supervising-bill-pay-services/.
Posted by RCC
Labels: Custody, Sample Forms
Tagged: 3, Bill Pay, Custody, Sample Forms
