On March 4th, the SEC issued a Risk Alert and Investor Bulletin on compliance with its custody rule for investment. The Office of Compliance Inspections and Examinations alert comes after a review of recent examinations found significant custody-related deficiencies in about one-third of the firms examined. Deficiencies included the adviser's failure to recognize it had custody; failure to meet the custody rule's surprise examination requirements; and failure to satisfy the custody rule's qualified custodian requirements. In addition, for advisers to audited pooled investment vehicles, the examinations found that some failed to meet requirements to engage an independent accountant and demonstrate that financial statements were distributed to all fund investors. Recent findings of custody deficiencies have resulted in a range of actions, including remedial measures by advisers, such as drafting, amending or enhancing their written compliance procedures, policies or processes, changing their business practices, or devoting more resources or attention to custody issues. OCIE's National Exam Program also has made referrals to the Division of Enforcement. SEC Press Release.