The SEC Custody Rule 206(4)-2 trips small RIAs into 'surprise custody' every year without the advisor realizing — inadvertent SLOAs, retained bill-pay access for older clients, dashboards with firm-wide MoveMoney, MFA tokens bound to offices instead of people. Hedgehog charges $3K to check. ACA wants $10K+ for surprise-exam prep. This tool scans your practice against 12 known trap scenarios in 30 seconds, flags exposures with rule citations, and generates a remediation memo with your surprise-exam gating decision. $149 one-time.
Answers 5 quick questions about your SLOAs, bill-pay, custodian dashboard, and ADV Item 9. Output: flagged exposures + remediation memo + surprise-exam gating decision.