Access Person, including any brokerage confirmation or account statements provided in lieu of the reports. 5. A record of the names of all persons who were Access Persons. 6. A record of any decision and the reason supporting the decision to approve the acquisition by the Access Person of initial public offerings and limited offerings. H Internal Control Records 1 Functions and Responsibilities. Organizational charts, Permanently Best personnel lists, and other documents describing the Practices functions and responsibilities of each department and each employee. 2 Written Policies and Procedures for the Prevention of Insider Permanently Section 204A Trading, including any related memorandums. 3 Compliance Manual. A copy of a written compliance manual Each version Rule that contains: maintained Duty to for five years Supervise (a)Policies and Procedures. Policies and procedures Section reasonably designed to prevent violations, by the 203(e)(6) Investment Adviser and its supervised persons, of the Investment Advisers Act and its rules (as well as other applicable laws); and (b)Compliance Responsibilities. The identification of persons responsible for meeting the applicable regulatory requirements and their supervisors. Annual Compliance Review. 4 Records documenting the 5 Rule Investment Adviser’s annual review of its compliance policies and procedures. 5 Annual Certifications. Annual employee certifications of 5 years (to Best compliance with insider trading and compliance policies mirror Practices and procedures. requirement of Rule 6 Personnel and Other Employee-Related Manuals, including any Permanently Best related memoranda. Practices Personnel Records, 7 including for each employee, officer and Permanently Best director (as applicable): Practices Dates of employment,
Access Person, including any brokerage confirmation or account statements provided in lieu of the reports. 5. A record of the names of all persons who were Access Persons. 6. A record of any decision and the reason supporting the decision to approve the acquisition by the Access Person of initial public offerings and limited offerings. H Internal Control Records 1 Functions and Responsibilities. Organizational charts, personnel lists, and other documents describing the functions and responsibilities of each department and each employee. Permanently Best Practices 2 Written Policies and Procedures for the Prevention of Insider Trading, including any related memorandums. Permanently Section 204A 3 Compliance Manual. A copy of a written compliance manual that contains: (a)Policies and Procedures. Policies and procedures reasonably designed to prevent violations, by the Investment Adviser and its supervised persons, of the Investment Advisers Act and its rules (as well as other applicable laws); and (b)Compliance Responsibilities. The identification of persons responsible for meeting the applicable regulatory requirements and their supervisors. Each version maintained for five years Rule Duty to Supervise Section 203(e)(6) 4 Annual Compliance Review. Records documenting the Investment Adviser’s annual review of its compliance policies and procedures. 5 Rule 5 Annual Certifications. Annual employee certifications of compliance with insider trading and compliance policies and procedures. 5 years (to mirror requirement of Rule Best Practices 6 Personnel and Other Employee-Related Manuals, including any related memoranda. Permanently Best Practices 7 Personnel Records, including for each employee, officer and director (as applicable): Dates of employment, Permanently Best Practices
RIA_procedures_manual_March_09.docx