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9C(3) Annual surprise examination of client assets

Form ADV Part 1A field explainer

Form ADV Part 1A Item 9C(3) · Answer type: yn · Item 9 - Compliance

What this means

Item 9C(3) asks whether an independent public accountant conducts an annual surprise examination of client funds and securities.

The examination is not scheduled for a date known to the adviser. The accountant examines client funds and securities covered by the engagement.

The checkbox reports whether this procedure occurs. It does not give the examination scope, result, exceptions, or findings.

Yes

The firm reports that an independent public accountant conducts the annual surprise examination described by this item.

No

The firm reports No under 9C(3). The checkbox does not explain why this procedure is not reported.

Official Form ADV question

9C(3) - An independent public accountant conducts an annual surprise examination of client funds and securities (Yes / No).

This checkbox is part of Item 9C, which reports custody compliance procedures.

Why it matters

This field identifies one reported custody procedure. It is useful only when read with the custody basis in Item 9A, the affected assets and clients, and the other Item 9C and 9D answers.

A Yes does not report the accountant's findings or establish that all custody controls are effective. A No does not by itself show that the firm failed to follow an applicable requirement.

How to read a firm's answer

Yes

Review Item 9A for the custody arrangement and the other Item 9C rows for procedures the firm reports. If this field affects an account you are considering, request the latest examination date and ask whether the accountant reported exceptions.

No

Review Item 9A and the remaining Item 9C and 9D rows before drawing a conclusion. The Form ADV panel may show another reported custody arrangement or procedure.

Related questions

Sources

  • Form ADV Part 1A, Item 9C (Custody Compliance)
  • Firm ADV form on Best Investors (Item 9 custody section)