Financial and/or Disclosure Issues Monthly Review for any Rule 206(4)-4 CCO/ – potential occurrence of items requiring disclosure Compliance Manual-COE Senior Mgmt./ CFO/COO QUARTERLY SEPTEMBER MONTHLY Form ADV Disclosures- Review to determine whether any CCO changes occurred at COMPANY that may require a prompt (within 30 days of month-end) amendment. Monthly email review conducted. Compliance Manual CCO/ Email Review – Performance/Valuation Calculations Monthly review for Compliance Manual CFO/Admin/ – calculations and reporting accuracy. CCO Monthly review of electronic Compliance Manual CCO/ Personal Trading Reports – –COE system checked for personal securities transactions compliance Risk Management / Investment Guidelines Monthly Risk Compliance Manual CCO/ – Committee reviews compliance with risk parameters, investment Risk Com restrictions, and general portfolio assessments Financial and/or Legal Disclosure Issues Monthly Review for Rule 206(4)-4 CCO/ – any potential occurrence of items requiring disclosure Compliance Manual-COE Senior Mgmt./ CFO/COO OCTOBER
Financial and/or Disclosure Issues – Monthly Review for any potential occurrence of items requiring disclosure Rule 206(4)-4 Compliance Manual-COE CCO/ Senior Mgmt./ CFO/COO QUARTERLY SEPTEMBER MONTHLY Form ADV Disclosures- Review to determine whether any changes occurred at COMPANY that may require a prompt (within 30 days of month-end) amendment. CCO Email Review – Monthly email review conducted. Compliance Manual CCO/ Performance/Valuation Calculations – Monthly review for calculations and reporting accuracy. Compliance Manual CFO/Admin/ CCO Personal Trading Reports – Monthly review of electronic system checked for personal securities transactions compliance Compliance Manual –COE CCO/ Risk Management / Investment Guidelines – Monthly Risk Committee reviews compliance with risk parameters, investment restrictions, and general portfolio assessments Compliance Manual CCO/ Risk Com Financial and/or Legal Disclosure Issues – Monthly Review for any potential occurrence of items requiring disclosure Rule 206(4)-4 Compliance Manual-COE CCO/ Senior Mgmt./ CFO/COO OCTOBER