ELEVATING YOUR CONFIDENCE

Our services for money managers include all the services you would expect from a compliance function at a large asset manager.

One of our employees will serve as your CCO with primary support from a program manager who leverages the rest of the team. In addition to policies, procedures, testing and reporting, we also manage all SEC exams with an on-site team during the entire course of the exam and commit to a 24-hour turnaround time for the review of marketing materials. We use a licensed system (at no additional cost to you) to manage all code of ethics and personal trading reporting. Clients also love that we include ongoing consulting support. Our offering includes all of the services that the SEC expects of a compliance program, so you shouldn’t expect any “out-of-scope” service invoices.

1

Chief Compliance Officer

We designate a member of our staff (acceptable to management) to serve as chief compliance officer pursuant to Rule 206(4)-7. The CCO is responsible for administering the adviser’s policies and procedures, reporting to management and staff, providing the annual written compliance report, and any other matters required of a CCO under the Investment Advisers Act.

2

Relationship Manager

We designate a member of our team to serve as your designated relationship manager (“RM”). The RM is responsible for delivering our services and ensuring that we meet your expectations.

3

Policies and Procedures

We proactively maintain and update the adviser’s compliance manual to reflect regulatory changes and changes to the adviser’s business. We draft all policies and work with management to include all recommended revisions and changes. We monitor the industry and regulatory developments and recommend changes to policies and procedures as appropriate.

4

Compliance Review

We conduct the annual review of the adequacy and effectiveness of the policies and procedures of the adviser as required by Rule 206(4)-7. The review includes a review of the policies and procedures, interviews of key personnel, obtaining certifications, reviewing internal and/or third-party compliance and internal control reports, reviewing cited regulatory deficiencies and/or exam results, noting observed risks, and testing implementation.

5

Compliance Report

We prepare a detailed written report of our annual compliance program review. The report includes a comprehensive testing matrix accompanied by a written report discussing the most significant issues. The report also describes remediation efforts with respect to prior years’ findings. We then discuss the report with management at an in-person meeting.

6

Compliance Calendar

We create, implement, and follow a detailed compliance calendar and project plan to ensure the timely completion of all compliance activities by all relevant parties.

7

Advice, Guidance, and Support

We provide real-time advice and guidance to management and staff with respect to any compliance and regulatory question.

8

Form ADV

We prepare and file all routine ADV amendments and state notice filings.

9

Section 13 Filings

We prepare and file all required Section 13 filings.

10

CRD/Licensing

We ensure the filing and recording of all forms related to securities licensing of employees.

11

Certifications

We ensure that all relevant personnel and service providers receive and understand the compliance policies and procedures and obtain certifications with respect thereto.

12

Marketing Materials

We review marketing materials for SEC compliance.

13

Code of Ethics and Insider Trading

We utilize our proprietary technology and process to manage all code of ethics and insider trading activities including preclearance and reviews of trading.

14

Training

We provide training on topics relevant to the compliance program.

15

Email Review

We review emails as required by the policies and procedures.

16

On-Site Testing

We conduct on-site visits for testing and other scheduled compliance activities.

17

Compliance Committee

We convene and conduct quarterly meetings of an internal Compliance Committee composed of senior managers. The Compliance Committee addresses material compliance issues and discusses the compliance plan. We take and retain minutes.

18

Regulatory Exams

We provide support related to responding to regulatory exams conducted by the SEC. This includes assembling materials in response to requests, interfacing with the exam staff, and preparing a written response to deficiencies.

19

Risk Assessment

We collaborate with management to conduct an annual risk assessment including an assessment of likelihood and impact of given business risks such as infrastructure, human resources, portfolio management, performance, expenses, and service providers.

20

Cybersecurity Assessment

We deploy our CyberSecure process (with Align Cybersecurity) to assess your cybersecurity policies and governance framework and your IT architecture, network and related technologies. The CyberSecure process also includes written recommendations and recommended policies.