Whether launching a new fund and planning to raise capital or operating an established fund with significant assets under management, we help funds and organizations meet custody requirements and investor demand for transparency.

SOLUTIONS THAT SATISFY REGULATORY REQUIREMENTS
Our Fund Custody service provides solutions for funds seeking an independent qualified custodian in accordance with rule 206(4)-2, the Custody Rule under the Investment Advisers Act of 1940. The Custody Rule requires registered investment advisers that have custody of client funds or securities to maintain those assets with a qualified custodian.

Custody rule’s key requirements include:
•Use of a “qualified custodian” to hold client assets
•Notices to clients detailing how their assets are being held
•Account statements for clients detailing their holdings
•Annual surprise exams
•Additional requirements when a related qualified custodian is used
•The audit approach for advisers of pooled investment vehicles

How Institutions May Benefit by Using Our Custody Services:

REGULATORY
Custody of assets under SEC Rule 206(4)-2 under the Investment Advisors Act of 1940 (Custody Rule)

REDUCE OPERATING BURDEN
Millennium Trust holds title to assets and cash funds, centralizing contact for fund investments

ENHANCED TRANSPARENCY
Quarterly statements showing fund-level cash flow

COOPERATION WITH AUDITOR FOR REGULATORY REVIEWS
Supports regulatory reviews for Custody Rule

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