Form ADV Part 1 - Custody

The questions below correspond to Item 9 of the Form ADV Part 1. 

Note that if you leave a question blank or do not answer a question, we will assume the answer to it is "no."

All responses should be as of the end of your most recent fiscal year (for most firms that is December 31).  If you completed this form last year, we will seek clarification or additional information.

If you are a SEC-registered firm, do not answer "yes" to any custody questions if you have custody solely because you deduct your advisory fees directly from your clients' accounts, or a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the presumption that you are not operationally independent from the related person.