Investor Statements / Fee Calculations- Quarterly Review and Advisers Act Section 204, CFO, verification of NAV calculations; documentation supporting Rule 204-2 IR, CCO calculations retained from all responsible parties. Compliance Manual - Quarterly documentation regarding the review of Advisers Act Rule 204-2 Senior Mgmt. CCO CCO’s email. Personal Trading Certifications Quarterly collected from access Advisors Act Rule 204A-1 CCO – persons for personal securities transactions. Compliance Manual Insider Trading/Restricted List - Quarterly Review and Compliance Manual CCO Maintenance of List; Verification of employee and 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 Funds. 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 Best Execution Quarterly audit of securities transactions to Compliance Manual CCO/ – examine factors related to Best Execution. Review and Brokerage & modifications to Brokers” List. “Approved Execution Com Errors - Quarterly Review of Trade Blotters, including Trade Advisers Act Rule 204-2 CCO Errors and actions deemed necessary Compliance Manual Soft Dollar Report Report of all soft dollar arrangements and Compliance Manual COO/CCO – compliance with Section 28(e).
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, IR, CCO CCO - 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 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 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 Funds. Compliance Manual CCO/ Valuation Comm. 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 Best Execution – Quarterly audit of securities transactions to examine factors related to Best Execution. Review and modifications to “Approved Brokers” List. Compliance Manual CCO/ Brokerage & Execution Com Errors - Quarterly Review of Trade Blotters, including Trade Errors and actions deemed necessary Advisers Act Rule 204-2 Compliance Manual CCO Soft Dollar Report – Report of all soft dollar arrangements and compliance with Section 28(e). Compliance Manual COO/CCO
Sample_Compliance_Calendar2012.docx