4 Powers of Attorney. All powers of attorney and other 5 Rule evidences of the granting of discretionary authority by any client to the Investment Adviser (or copies). This requirement should be satisfied simply by keeping all limited partnership agreements as well as any specific advisory agreements. 5 Written Communications. Originals of all written 5 (from Rule communications received and copies of all written time of last communications sent by the Investment Adviser relating publication to: or (a)Any recommendations or advice made or proposed to for be made; marketing (b)Any receipt, disbursement or delivery of funds or and similar securities; or materials) placing or execution of any order to purchase or sell any security. These communications include: Marketing materials, circulars and research reports; Notices to custodians; Periodic statements sent to clients; Fee invoices; Trade confirmations, if any; and Principal and agency transaction consents, if any. (Note: an Investment Adviser need not keep any unsolicited market letters and similar communications of general public distribution not prepared for or by the Investment Adviser.) 6 Complaint File. A client correspondence or complaint file. 5 years Rule generally. F Marketing-Related Records 1 Marketing Materials. A copy of each notice, circular, 5 years after Rule advertisement, newspaper article, investment letter, the end of bulletin or other communication that the Investment the fiscal Adviser circulates or distributes, directly or indirectly, to year when 10 or more persons (other than persons connected with last used the Investment Adviser).
4 Powers of Attorney. All powers of attorney and other evidences of the granting of discretionary authority by any client to the Investment Adviser (or copies). This requirement should be satisfied simply by keeping all limited partnership agreements as well as any specific advisory agreements. 5 Rule 5 Written Communications. Originals of all written communications received and copies of all written communications sent by the Investment Adviser relating to: (a)Any recommendations or advice made or proposed to be made; (b)Any receipt, disbursement or delivery of funds or securities; or placing or execution of any order to purchase or sell any security. These communications include: Marketing materials, circulars and research reports; Notices to custodians; Periodic statements sent to clients; Fee invoices; Trade confirmations, if any; and Principal and agency transaction consents, if any. (Note: an Investment Adviser need not keep any unsolicited market letters and similar communications of general public distribution not prepared for or by the Investment Adviser.) 5 (from time of last publication or for marketing and similar materials) Rule 6 Complaint File. A client correspondence or complaint file. 5 years Rule generally. F Marketing-Related Records 1 Marketing Materials. A copy of each notice, circular, advertisement, newspaper article, investment letter, bulletin or other communication that the Investment Adviser circulates or distributes, directly or indirectly, to 10 or more persons (other than persons connected with the Investment Adviser). 5 years after the end of the fiscal year when last used Rule
RIA_procedures_manual_March_09.docx