MONTHLY Form ADV Disclosures- Review to determine whether any CCO changes occurred at COMPANY that may require a prompt (within 30 days of amendment. Email Review Monthly email review conducted. Compliance Manual CCO/ – Performance/Valuation Calculations Monthly review for Compliance Manual – calculations and reporting accuracy. CCO Personal Trading Reports Monthly review of electronic Compliance Manual CCO/ – –COE system checked for personal securities transactions compliance Risk Management / Investment Guidelines Monthly Risk Compliance Manual CCO/ – Committee reviews compliance with risk parameters, investment Risk Com restrictions, and general portfolio assessments 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 advertising/sales 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 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. Heads access controlled. Review of Books and Records maintenance and storage.
MONTHLY Form ADV Disclosures- Review to determine whether any changes occurred at COMPANY that may require a prompt (within 30 days of amendment. CCO Email Review – Monthly email review conducted. Compliance Manual CCO/ Performance/Valuation Calculations – Monthly review for calculations and reporting accuracy. Compliance Manual CCO Personal Trading Reports – Monthly review of electronic system checked for personal securities transactions compliance Compliance Manual –COE CCO/ Risk Management / Investment Guidelines – Monthly Risk Committee reviews compliance with risk parameters, investment restrictions, and general portfolio assessments Compliance Manual CCO/ Risk Com 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 advertising/sales 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. Heads
Sample_Compliance_Calendar2012.docx