4 Powers of Attorney. All powers of attorney and other evidences of the granting of discretionary authority by any client to the Investment Adviser (or copies). This requirement should be satisfied simply by keeping all limited partnership agreements as well as any specific advisory agreements. 5 Rule 5 Written Communications. Originals of all written communications received and copies of all written communications sent by the Investment Adviser relating to: (a)Any recommendations or advice made or proposed to be made; (b)Any receipt, disbursement or delivery of funds or securities; or placing or execution of any order to purchase or sell any security. These communications include: Marketing materials, circulars and research reports; Notices to custodians; Periodic statements sent to clients; Fee invoices; Trade confirmations, if any; and Principal and agency transaction consents, if any. (Note: an Investment Adviser need not keep any unsolicited market letters and similar communications of general public distribution not prepared for or by the Investment Adviser.) 5 (from time of last publication or for marketing and similar materials) Rule 6 Complaint File. A client correspondence or complaint file. 5 years Rule generally. F Marketing-Related Records 1 Marketing Materials. A copy of each notice, circular, advertisement, newspaper article, investment letter, bulletin or other communication that the Investment Adviser circulates or distributes, directly or indirectly, to 10 or more persons (other than persons connected with the Investment Adviser). 5 years after the end of the fiscal year when last used Rule
Access Person, including any brokerage confirmation or account statements provided in lieu of the reports. 5. A record of the names of all persons who were Access Persons. 6. A record of any decision and the reason supporting the decision to approve the acquisition by the Access Person of initial public offerings and limited offerings. H Internal Control Records 1 Functions and Responsibilities. Organizational charts, personnel lists, and other documents describing the functions and responsibilities of each department and each employee. Permanently Best Practices 2 Written Policies and Procedures for the Prevention of Insider Trading, including any related memorandums. Permanently Section 204A 3 Compliance Manual. A copy of a written compliance manual that contains: (a)Policies and Procedures. Policies and procedures reasonably designed to prevent violations, by the Investment Adviser and its supervised persons, of the Investment Advisers Act and its rules (as well as other applicable laws); and (b)Compliance Responsibilities. The identification of persons responsible for meeting the applicable regulatory requirements and their supervisors. Each version maintained for five years Rule Duty to Supervise Section 203(e)(6) 4 Annual Compliance Review. Records documenting the Investment Adviser’s annual review of its compliance policies and procedures. 5 Rule 5 Annual Certifications. Annual employee certifications of compliance with insider trading and compliance policies and procedures. 5 years (to mirror requirement of Rule Best Practices 6 Personnel and Other Employee-Related Manuals, including any related memoranda. Permanently Best Practices 7 Personnel Records, including for each employee, officer and director (as applicable): Dates of employment, Permanently Best Practices