Investor Eligibility - Quarterly Review of New Investor files to Compliance Manual CCO determine compliance with Reg D Books And Records - Quarterly Review and verification that Advisers Act Rule 204-2 CCO /Admin required Books and Records are properly maintained, stored, and Compliance Manual Dept. access controlled. Review of Books and Records maintenance and storage. Investor Statements / Fee Calculations- Quarterly Review and Advisers Act Section 204, CFO, Admin, verification of NAV calculations; documentation supporting Rule 204-2 IR, CCO calculations retained from all responsible parties. Compliance Manual CCO Email - Quarterly documentation regarding the review of Advisers Act Rule 204-2 Senior Mgmt. CCO’s email. Personal Trading Certifications Quarterly collected from access Advisors Act Rule 204A-1 CCO – persons for their personal securities transactions. Compliance Manual Insider Trading/Restricted List - Quarterly Review and Compliance Manual CCO Maintenance of List; Verification of employee and Third Party Insider Trading compliance Proxy Voting- Quarterly review that proxies have been voted and Compliance Manual CCO/ Inv. Team records retained as required. ERISA Restrictions-Reporting, controls and compliance DDQ CCO/CFO Valuations Quarterly Valuation Committee review and Compliance Manual CCO/ Valuation – assessment of specific issues related to valuations. Formal Comm. valuation of Private Assets in the Trade Allocation Quarterly Review by Brokerage & Execution Compliance Manual CCO/ – Committee and CCO to ensure compliance with allocation Brokerage & policies. CCO will document the review. Execution Com
Investor Eligibility - Quarterly Review of New Investor files to determine compliance with Reg D Compliance Manual CCO Books And Records - Quarterly Review and verification that required Books and Records are properly maintained, stored, and access controlled. Review of Books and Records maintenance and storage. Advisers Act Rule 204-2 Compliance Manual CCO /Admin Dept. Investor Statements / Fee Calculations- Quarterly Review and verification of NAV calculations; documentation supporting calculations retained from all responsible parties. Advisers Act Section 204, Rule 204-2 Compliance Manual CFO, Admin, IR, CCO CCO Email - Quarterly documentation regarding the review of CCO’s email. Advisers Act Rule 204-2 Senior Mgmt. Personal Trading Certifications – Quarterly collected from access persons for their personal securities transactions. Advisors Act Rule 204A-1 Compliance Manual CCO Insider Trading/Restricted List - Quarterly Review and Maintenance of List; Verification of employee and Third Party Insider Trading compliance Compliance Manual CCO Proxy Voting- Quarterly review that proxies have been voted and records retained as required. Compliance Manual CCO/ Inv. Team ERISA Restrictions-Reporting, controls and compliance DDQ CCO/CFO Valuations – Quarterly Valuation Committee review and assessment of specific issues related to valuations. Formal valuation of Private Assets in the Compliance Manual CCO/ Valuation Comm. Trade Allocation – Quarterly Review by Brokerage & Execution Committee and CCO to ensure compliance with allocation policies. CCO will document the review. Compliance Manual CCO/ Brokerage & Execution Com
Sample_Compliance_Calendar2012.docx