Holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them. You have custody…
Single name credit default swap, including loan credit default swap, credit default swap referencing a standardized basket of credit entities,…
The power, directly or indirectly, to direct the management or policies of a person, whether through ownership of securities, by…
Exposures to commodities that you do not hold physically, whether held synthetically or through derivatives (whether cash or physically settled).…
Any of your firm’s investment advisory clients. This term includes clients from which your firm receives no compensation, such as…
Being accused of a crime in a formal complaint, information, or indictment (or equivalent formal charge). [Used in: Part 1A,…
A written disclosure statement containing information about certain of your supervised persons that your firm is required by Part 2B…
A written disclosure statement that you must provide to clients and prospective clients. See SEC rule 204-3; Form ADV, Part…
Borrowings include secured borrowings and unsecured borrowings, collectively. Secured borrowings are obligations for borrowed money in respect of which the…
Within 90 days after your firm’s fiscal year end, your firm must file an “annual updating amendment,” which is an…