ELEVATING YOUR CONFIDENCE

We focus on compliance to give our clients the freedom and security to raise capital and serve their institutional and high-net-worth clients.

We undertake all the required regulatory functions including serving as chief compliance officer, reviewing decks for compliance with SEC advertising rules, reviewing emails, and assisting with LP communications. We use a system we licensed to collect required personal trading reports, manage trading lists, and pre-approve personal trading. We assume full ownership of the SEC exam process with our on-site team interfacing with the SEC, responding to requests and interviews, and responding to any cited deficiencies. When our clients receive due diligence requests from institutional investors, we serve as a credible compliance voice in responding to written submissions or interview requests. In coordination with the client services team, we help prepare responses to concerns raised by current LPs.

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 GP/manager’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 GP/Managers 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 GP/manager’s compliance manual to reflect regulatory changes and changes to the GP/manager’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 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 provide 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 the Board 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

Certifications

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

10

Marketing Materials

We review all fund marketing materials for compliance with SEC and FINRA rules.

11

Fundraising and Client Service Materials

We review all fundraising documents, including deck books and PPMs, as well as client service reports for compliance with SEC rules.

12

LPA Committees

We assist in the preparation of agendas and presentation materials to ensure regulatory compliance and consistency with the LPA.

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 manage all 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 companies, 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.