Focused comparison
Australia custody/client assets vs United States custody/client assets
A focused comparison for custody/client assets businesses choosing between Australia and United States.
| Question | Australia | United States |
|---|---|---|
| Likely route | AFSL custody, depository, client money, and responsible entity analysis | Investment adviser custody rule, qualified custodian, broker-dealer custody, and state custody analysis |
| Key people | Responsible managers with appropriate competence and organisational capacity Authorised representatives where services are provided under another licensee | Investment adviser representatives may require state registration depending on facts Broker-dealer registered representatives require firm sponsorship, CRD filing, exams, and registration |
| Corporate evidence | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers | Custody and client assets; Capital and financial resources; Compliance framework; Outsourcing and vendors; Regulatory reporting; Official-source route memo; Public register verification plan; Questions log for qualified advisers |
| Capital/resources | Financial resource expectations depend on authorisations, financial products, client money/custody, and licensee obligations. | Adviser capital rules are usually state-specific or tied to custody and other facts; broker-dealers face SEC net capital and FINRA membership expectations. |
| Timeline | Often 4 to 8+ months depending on authorisations and proof quality. | SEC adviser registration can become effective in about 45 days if complete; FINRA new member review may run up to 180 calendar days for substantially complete applications. |
| Common bottlenecks | Requested authorisations are broader than the actual operating plan can support Responsible manager evidence is thin or not matched to all authorisations | Broker-dealer issues hidden inside compensation, solicitation, placement, or transaction workflows Custody, private fund audit, and fee deduction arrangements not fully analysed |