sec surprise exam consultants


The SEC continues to expand regulations impacting Registered Investment Advisors (RIA) when an RIA has custody of client assets. FGMK is registered with the PCAOB and has the expertise to guide you through this ever changing landscape to ensure that your independent surprise custody examination complies with these regulations.

Our extensive custody experience encompasses fee-only registered investment advisory, advisors who manage pooled investment vehicles, family office and multi-family office advisors with complementary bill-pay services, and everything in between. Our team of senior professionals is quick to learn and understand the custody issues concerning you. We then design procedures to ensure the custody audit is efficiently performed and that you remain in compliance with SEC Rule 206(4)-2 and 204-2(b).

FGMK provides the following additional services to RIA’s:


Pooled investment vehicles managed by RIA’s may qualify for an exception to the independent surprise custody examination rules by obtaining financial statements audited in accordance with GAAP. FGMK is a PCAOB registered firm with a financial services team ready to independently perform audits that meet SEC requirements.


FGMK’s Fund Administration Practice provides accounting, administration and reporting services. Fund Administration provides services to entities of all types, including:

  • CTAs/CPOs
  • Private equity and venture capital funds
  • Public and private alternative investment partnerships and LLCs

Our wide array of deliverables includes investor statements, fund-level reporting, sector based schedules, daily NAV distribution and daily risk analysis. Fund Administration provides clean and customizable options for fund managers to communicate their results and commentary to their investors on a regular and timely basis. Working together allows you to perform at your best without needing to burden yourself with the necessary back-office functions.


If your organization serves as a qualified custodian or provides outsourced services of any type, you may need a Service Organizational Control (SOC) report to provide assurance to your clients that your organization is taking proper measures to protect their assets under your control. SOC reporting will allow your organization to differentiate itself in the marketplace, attract top customers and to remain in compliance with SEC rules and regulations. FGMK’s Risks and Controls group has extensive experience with SOC readiness and SOC reporting engagements.


Our tax professionals are proactive in advising on taking advantage of credits and incentives available to RIA’s, both on the federal and state level. As you contemplate an exit, we will develop a tax-efficient exit plan for your stakeholders.