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 Advertising Materials - Quarterly review of compliance with Advisers Act Rule 206(4) and CCO literature policies and procedures Best Practices Compliance Manual Investor Eligibility - Quarterly Review of New Investor files to Compliance Manual CCO determine compliance with Reg D - Quarterly Review and verification that Advisers Act Rule 204-2 CCO /Admin Books And Records 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 - 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 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
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 Advertising Materials - Quarterly review of compliance with literature policies and procedures Advisers Act Rule 206(4) and Best Practices Compliance Manual CCO 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 - 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 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
Sample_Compliance_Calendar2012.docx