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Compliance Considerations for Custody

October 27, 2020
10:45 AM - 12:00 PM CDT
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Course Description:

Custody remains one of the most complex subjects for investment advisers. From brand-new start-ups to well established industry leaders, it seems that everyone still has questions about applying custody rules and guidance to their own situations. One thing is certain – you need procedures to ensure the question of custody is never addressed on an ad hoc basis. In this session we will explore the various ways in which a firm may have custody (including first- and third-party transfers) and discuss how firms have designed their procedures to address “accidental custody.”

Learning Objectives

After attending this session, attendees should be able to:

  • Pinpoint when and how you may be deemed to have custody
  • Address issues that have arisen since the SEC’s most recent guidance was adopted in 2017
  • Prevent and detect instances of “accidental custody”

This virtual course is being taught as part of the Fall 2020 Compliance Conference. To learn more, visit our main conference webpage.

Elizabeth Knoblock
Elizabeth M. Knoblock
Managing Member and OwnerElizabeth M. Knoblock, PLLC


Elizabeth M. Knoblock is the managing member and sole owner of Elizabeth M. Knoblock, PLLC, a private law firm. She is a securities lawyer with over 35 years of legal practice and business experience.

As first noted in the 2007 edition of Chambers USA, Ms. Knoblock has the “…ability to see the business viewpoint and to interact with management on difficult issues….” Over the course of her career, she has focused on the laws governing investment advisers, registered investment companies, hedge funds and private accounts, including institutional, retail and wrap fee clientele.

Ms. Knoblock has significant experience with securities-related policies and procedures, disclosure, compliance and regulatory issues. Ms. Knoblock began her regulatory career with the Office of General Counsel of the Commodity Futures Trading Commission, followed by a stint with the Division of Investment Management of the Securities and Exchange Commission, before moving to Wall Street, where she spent five years in various legal positions with dual registrant brokerage firms, including Kidder Peabody, Gruntal and Shearson Lehman Hutton.

She subsequently served for a decade as General Counsel of Templeton Investment Counsel, Inc. in Florida and for more than a decade as a partner with two separate international law firms. In addition to managing her firm, Ms. Knoblock is a past Board member of the National Society of Compliance Professionals and a much sought after speaker at industry conferences. She was honored by National Regulatory Services, an industry compliance service provider, as the only speaker to have been invited to speak, and to have spoken, for 30 consecutive years at its national compliance conferences.

Ms. Knoblock is a member of the state bars of New York, Florida, Alabama and the District of Columbia. Her educational degrees include a magna cum laude Dean’s List Bachelor of Arts from Stetson University in Deland, FL; a Dean’s List Juris Doctor from Georgetown University Law Center in Washington, DC; and an LLM / Masters in Securities Regulation, also from Georgetown, plus a Dean’s List MBA from NOVA University, both of which were obtained while working full-time as a securities lawyer.


John Van Der Wal
John Van Der Wal
ConsultantNRS


John Van Der Wal brings over 20 years of compliance and industry related experience to NRS. Prior to joining NRS in 2014, John was president and founder of Compliance Advisory Services, LLC for 12 years, providing compliance consulting services to SEC and State registered investment advisors and broker-dealers. He has worked in a variety of securities and investment related environments, including financial services, asset management and consulting. John also spent 3 years with FINRA, conducting reviews and oversight of member firms from its San Francisco District Office.

John earned his undergraduate degree from the University of California at Davis and received an MBA from the University of San Francisco.


Rob Stirling
Robert Stirling
Executive ConsultantNRS


Rob Stirling has worked with NRS as a Senior Consultant for much of the past four decades: from October 1991 to June 2000, from May 2002 to June 2004, on a part-time basis staring in December 2007, and returning full-time in August 2008.

Rob is based in Miamisburg Ohio and has prepared, reviewed and/or updated hundreds of ADVs representing firms of all sizes and engaged in every aspect of investment advisory services. He has helped design and monitor specialized compliance programs for advisers to private investment vehicles (including hedge funds, funds-of-funds and private equity funds), advisers based in Europe and Asia doing business in the United States, and Internet-based advisers.

He regularly reviews advertising and marketing materials, including websites, for compliance with SEC guidelines. Rob has performed well over two hundred mock examinations of advisory firms, and he has spoken at numerous compliance conferences and seminars.

During his times away from NRS, Rob was himself a compliance officer. Rob was Chief Compliance Officer of PrivateAccounts, Inc. from July 2000 to October 2000, when Private Accounts, Inc. was purchased by E*TRADE Financial, where Rob worked as a Compliance Manager from November 2000 to May 2002. Rob was Chief Compliance Officer and General Counsel of Eubel Brady & Suttman Asset Management, Inc. of Dayton, Ohio from June 2004 through July 2008. Rob’s experience as a CCO allows him to bring a practical, real-world approach to addressing compliance matters facing investment advisers of all sizes.

Rob graduated from the American University with a Bachelor of Arts in Religion and received a Juris Doctor degree from the University Of Connecticut School Of Law. Rob is admitted to the Connecticut bar.


For Whom: Designed to increase the professional competence of Investment Advisers.

Suggested Skill Level: Intermediate

Maximum Recommended Credit Hours for this session will include CLE, IACCP® and CPE .

CA MCLE = 75 minutes
IACCP® = 75 minutes
CPE = 75 minutes