Form ADV-E
Form ADV-E is the certificate of accounting filed in connection with the surprise examination of an investment adviser that has custody of client funds or securities. The independent public accountant performing the surprise examination files it, and files it again with a statement if the engagement terminates.
- Who handles it
- The independent public accountant conducting the surprise examination, on behalf of an adviser with custody.
- Filed through
- IARD
- Applies to
- SEC-registered RIA, State-registered RIA
What the form asks for
- Identifying information for the adviser and the accountant
- Date of the surprise examination
- The accountant's certificate
- Statement of termination where applicable
The work behind the filing
Assemble the custody population before the examiner arrives
A surprise examination starts with an accurate list of the accounts and assets the firm is deemed to have custody of. That determination spans the custodian, the portfolio system, and the standing letters of authorization sitting in the document store. Caddi can maintain that population continuously instead of rebuilding it under a deadline.
Keep the SLOA inventory current
Standing letters of authorization are the most common reason a firm has custody without realizing it. They arrive as signed documents and then go quiet. Caddi can extract and track them from the document store so the custody determination reflects reality.
Questions
What is Form ADV-E?
Form ADV-E is the certificate of accounting filed with the surprise examination of an adviser that has custody of client funds or securities. The independent public accountant performing the examination files it.
Who files Form ADV-E, the adviser or the accountant?
The independent public accountant files Form ADV-E in connection with the surprise examination, though the adviser is responsible for arranging the examination.
Does every RIA need a surprise examination?
No. The requirement is tied to having custody of client funds or securities as defined by the custody rule. Determining whether the firm has custody is the part firms most often get wrong.
Does Caddi file this form for me?
No. Caddi does not submit filings to IARD, FINRA Gateway, EDGAR, or any regulator, and it is not a substitute for your compliance program or your CCO. Caddi automates the work around the filing: gathering the underlying data out of your portfolio, CRM, and document systems, reconciling it against the prior filing, flagging what changed, and evidencing delivery. A human still reviews and files.
Related forms
The filing is the easy part
Caddi does not file forms. It runs the work around them: pulling the underlying data out of your portfolio, CRM, and document systems, reconciling it against the prior filing, and evidencing delivery. See it run on your own stack.
See the compliance specialistThis page describes what the form is and the work it creates. For requirements, deadlines, and whether any of it applies to your firm, see SEC — Form ADV-E.