jmoore

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jmoore
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  • My experience has always been if you or your Firm can not exercise control or disbursement of funds then custody does not exist. If the funds are made payable to the client's account then I do not believe custody exists.
  • Yes, they should be reviewed and how they are reviewed would depend a lot on the firm's size. A larger firm can designate a more senior and/or removed individual to review those emails. Most archival services allow you to carve out certain individ…