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Form ADV Part 1A Item 9C(1) · Answer type: yn · Item 9 - Compliance
Item 9C(1) asks whether a qualified custodian sends account statements at least quarterly to investors in pooled investment vehicles managed by the adviser.
This custody safeguard applies specifically to pooled investment vehicles like private funds, hedge funds, or other collective investment structures where the adviser manages assets for multiple investors through a single vehicle rather than separate individual accounts.
Quarterly custodian statements provide investors with a record sent by the qualified custodian. The checkbox does not establish that the custodian is unrelated to the adviser or that the statement independently validates every reported value.
The statement can be compared with reports from the adviser or fund administrator. Item 9C(1) does not report the statement contents or the effectiveness of this comparison.
Yes
The firm reports that a qualified custodian sends account statements at least quarterly to investors in pooled investment vehicles it manages.
No
The firm reports No and does not report this quarterly-statement procedure under 9C(1). The answer does not state why or identify any alternative procedure.
9C(1) - A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage (Yes / No).
This checkbox is part of Item 9C, which covers custody compliance safeguards that advisers must use when they have custody of client assets, particularly focusing on pooled investment vehicle arrangements.
The answer tells you whether the firm reports this statement-delivery procedure. Read it with the other Item 9C answers rather than treating it as proof of asset values or overall custody quality.
A Yes does not tell you what information the custodian statements contain, how detailed they are compared to adviser reports, whether all fund information is included, how quickly statements reflect trading activity, or what investors should do if custodian and adviser reports don't match.
Compare the custodian statement with the adviser or fund-administrator report for the same period. Ask which contact receives discrepancy reports and what correction process applies.
Yes
The adviser reports that custodians send quarterly statements to pooled vehicle investors. On Best Investors, find Item 9C on the firm’s ADV form panel and confirm 9C(1) is Yes. Also review 9C(3) surprise examination and Item 9 custody on the same profile for related custody safeguards.
If you invest in the adviser's pooled vehicles, ensure you receive and review both custodian statements and adviser reports, and understand what to do if you notice discrepancies.
No
The firm reports No under 9C(1). Check whether it reports managing pooled vehicles in 5G(4) pooled investment vehicles, then review neighboring 9C rows and 9D(1) acting as qualified custodian for other reported arrangements.
Also check 5F regulatory AUM to understand if most client assets are in separately managed accounts rather than pooled vehicles, which would have different custody arrangements.