regulatory compliance. He works extensively with investment firms on compliance issues, including investment adviser and broker dealer marketing regulations and the GIPS standards. He was previously the General Counsel to the CFA Institute and was responsible for overseeing the development of the GIPS and other standards governing Fund(s): investment funds managed by the Managers. Illiquid Funds or FIP(s): equity investment funds regulated by CVM Instruction 391/03, under the management and administration of the Managers. Compliance Manual or Manual: This document, with the compilation of the Compliance Policies, available to the general public. Compliance manuals are not reasonably tailored to the adviser's business practices. The staff noted that certain compliance programs did not take into account important individualized business practices such as the adviser's particular investment strategies, types of clients, trading practices, valuation procedures and advisory fees. According to Rule 206(4)-7 ("Rule 206(4)-7") of theInvestment Advisers Act of 1940 ("Advisers Act"), all investment advisers must adopt and implement written policies and procedures that are reasonably designed to prevent and detect the adviser and its personnel from violating the Advisers Act. RIA Compliance Consultants has developed the following sample compliance forms to assist investment advisers in maintaining the required books and records. The forms are delivered in Microsoft Word or PDF format and can easily be customized to fit your business. In this context, principal office and place of business is where the executive office of the investment adviser is located. This is where the officers, partners, or managers of the investment adviser direct, control, and coordinate the activities of the investment adviser. See SEC Rule 203A-3(c). Wilshire Associates Compliance Manual . 2 | Page. 1. Primary and general elections are considered separate elections. obligations require the Firm and its Personnel to provide investment adviser clients with full and fair disclosure of relevant facts and material potential or actual conflicts of interest. D. Compliance Manual Page 4 LLCRed Oak Compliance Solutions 888.302 .4594 redoakcompliance.com between the investment adviser and thirdparty (non- -employee) solicitor must be in place. It may also be necessary for the solicitor to become registered as an investment advisor representative of your adviser. Has your investment Compliance Manual Every Investment Adviser must develop and maintain written procedures that define the supervisory process the firm implements to assure compliance regarding: Acting on Insider Information Chinese Wall procedures, if applicable Trade allocation Monitoring personal securities transactions Pricing and valuation procedures advice on behalf of the investment adviser and is subject to the supervision or control of the investment adviser." 17 C.F.R. § 275.202(a)(25). 3 The recently proposed code of ethics rule for advisers, if adopted, would arguably increase the scope of an adviser's compliance programs to include compliance with the federal securities laws. This Compliance Manual is to be maintained by SFA's CCO in cooperation with the Chief Executive Officer ("CEO"), Department Manager(s) and other qualified persons of the firm. Additions and changes to the Compliance Manual will be announced as events occur r
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