Under the Uniform Securities Act, the threshold where a State-registered adviser is considered to have taken custody of client funds if it charges prepaid advisory fees, is:
The advisory fees will be "$500, 6 months or more in advance of rendering services".
Explanation:
Whenever a nation-registered investment manager recognizes $500 (and sometimes more) of advanced consulting fees, 6 months more than before anticipation of providing services, then perhaps the consultant is deemed to have obtained ownership of customer funds being defined by NASAA.
(In comparison, it should also be noted that perhaps the Advisers (investment) Act of year 1940 established the cap at $1,200 among Federal Covered consultants, although that wasn't the law for govt-registered consultants).