AML-Annual confirmation that Administrator conducts proper Bank Secrecy Act and USA CCO anti-money laundering procedures, including periodic screening PATRIOT Act of investor names against the OFAC list. Compliance Manual Privacy Notice-Annual Review and Delivery of COMPANY’s Regulation S-P CCO Privacy Notice. Compliance Manual COE -Annual Code of Ethics Policy and Compliance Manual Compliance Manual-COE CCO Certifications COE Annual Holdings Report - Access Persons submit Annual Rule 204A-1 CCO report for their personal securities holdings. Compliance Manual BCP Annual Review and Testing Yearly testing of Disaster Compliance Manual CCO /IT – Recovery Plan and Service Provider BCP (to extent possible) and discussion of any potential outstanding issues. Annual Review of CCO Performance Rule 206(4)-7(c) Senior Mgmt. Compliance Manual Annual Compliance Review Review of COMPANY’s Policies and Rule 206(4)-7 CCO – Procedures; Documentation of review begins. Compliance Manual Books And Records Annual Review and verification that Advisers Act Rule 204-2 CCO / – required Books and Records are properly maintained, stored, and Compliance Manual Other Dept. access controlled. Review of Books and Records maintenance Heads and storage. Annual Performance/Fee Calculation Review Rule 206(4)-1 Compliance Manual FEBRUARY MONTHLY Form ADV Disclosures- Review to determine whether any CCO changes occurred at COMPANY that may require a prompt (within 30 days of month-end) amendment.
AML-Annual confirmation that Administrator conducts proper anti-money laundering procedures, including periodic screening of investor names against the OFAC list. Bank Secrecy Act and USA PATRIOT Act Compliance Manual CCO Privacy Notice-Annual Review and Delivery of COMPANY’s Privacy Notice. Regulation S-P Compliance Manual CCO COE -Annual Code of Ethics Policy and Compliance Manual Certifications Compliance Manual-COE CCO COE Annual Holdings Report - Access Persons submit Annual report for their personal securities holdings. Rule 204A-1 Compliance Manual CCO BCP Annual Review and Testing – Yearly testing of Disaster Recovery Plan and Service Provider BCP (to extent possible) and discussion of any potential outstanding issues. Compliance Manual CCO /IT Annual Review of CCO Performance Rule 206(4)-7(c) Compliance Manual Senior Mgmt. Annual Compliance Review – Review of COMPANY’s Policies and Procedures; Documentation of review begins. Rule 206(4)-7 Compliance Manual CCO Books And Records – Annual 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 / Other Dept. Heads Annual Performance/Fee Calculation Review Rule 206(4)-1 Compliance Manual FEBRUARY MONTHLY Form ADV Disclosures- Review to determine whether any changes occurred at COMPANY that may require a prompt (within 30 days of month-end) amendment. CCO
Sample_Compliance_Calendar2012.docx