Wealth Management

Practical tips for preparing for a surprise custody exam

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For high-net-worth families and family offices, RIAs often support the practical side of financial life—coordinating bill payments, managing activity across multiple entities, and helping ensure money moves smoothly, securely, and with minimal disruption.

Yet some RIAs hesitate to offer bill pay because of questions about the SEC’s Custody Rule. The rule is meant to protect client assets, and bill pay involves access to client funds. 

At the same time, bill pay is a common, long-standing service. The regulatory expectations around it are well established, and when implemented thoughtfully, bill pay can strengthen client relationships and simplify day-to-day financial management.

This guide explains:

  • What a surprise examination is
  • Why it applies in certain bill pay scenarios
  • How RIAs can prepare.

Note: This guide is intended to provide general information, not legal or compliance advice, so firms can better understand expectations and plan accordingly. 

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