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Form ADV Part 1A Item 9D(1) · Answer type: yn · Item 9 - Compliance
Item 9D(1) asks whether the adviser acts as a qualified custodian for client assets.
A qualified custodian can include certain banks, registered broker-dealers, futures commission merchants, and foreign financial institutions that meet the applicable definition. Item 9D(1) reports whether the adviser itself acts in that role.
This answer distinguishes an adviser acting as the qualified custodian from an adviser that uses another custodian. The checkbox does not identify the assets involved or the controls that apply.
Acting as a qualified custodian is distinct from using another qualified custodian. The remaining Item 9 answers provide the available context about the firm's custody arrangement.
Yes
The firm reports that it acts as a qualified custodian. Review the other Item 9 answers for the reported custody scope and procedures.
No
The firm reports No and does not report acting as a qualified custodian under this item. This answer does not identify who holds client assets or prove that the adviser has only advisory authority.
9D(1) - You act as a qualified custodian (Yes / No).
This checkbox is part of Item 9D, which asks about qualified custodian roles reported by the adviser and related persons.
When 9D(1) is Yes, review the other Item 9 answers to identify the reported custody scope and procedures.
The specific requirements depend on the firm's role and custody arrangement. Item 9D(1) does not report insurance coverage, examination frequency, or the effectiveness of controls.
A Yes does not identify insurance, controls, account-statement delivery, examination results, or the financial condition of the custodian.
Review 9A for custody scope and 9C for reported procedures. Identify the legal entity acting as custodian and the entity that sends account statements.
Yes
Check 9A for custody scope, 9C for reported procedures, and 6A(7) and 7A(8) for separately reported banking activity or affiliations. Match the custodian name to the account agreement and statement issuer.
No
The firm reports No under 9D(1). Review 9A and the remainder of Item 9 to understand the custody arrangements it does report.
Look at Item 8 separately for the firm's reported brokerage authority and practices.