COMPANY, LLC - Compliance Calendar (2012) DATE ACTIVITY LEGAL BASIS RESPONSIBLE PERSON REVIEWED YES / NO COMMENTS JANUARY 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 Email Review – Monthly email review conducted. Compliance Manual CCO Performance/Valuation Calculations – Monthly review for calculations and reporting accuracy. Compliance Manual CCO Personal Trading Reports – Monthly review of electronic system checked for personal securities transactions compliance Compliance Manual –COE CCO Risk Management / Investment Guidelines – Monthly Risk Committee reviews compliance with risk parameters, investment restrictions, and general portfolio assessments Compliance Manual CCO/ Risk Com Financial and/or Legal Disclosure Issues – Monthly Review for any potential occurrence of items requiring disclosure Rule 206(4)-4 Compliance Manual-COE CCO/ Senior Mgmt./ CFO/COO QUARTERLY Advertising Materials - Quarterly review of compliance with advertising/sales literature policies and procedures Advisers Act Rule 206(4) and Best Practices Compliance Manual CCO Investor Eligibility - Quarterly Review of New Investor files to determine compliance with Reg D Compliance Manual CCO Books And Records - Quarterly 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 /Admin / Dept. Heads
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
Financial and/or Disclosure Issues – Monthly Review for any potential occurrence of items requiring disclosure Rule 206(4)-4 Compliance Manual-COE CCO/ Senior Mgmt./ CFO/COO QUARTERLY Advertising Materials - Quarterly review of compliance with literature policies and procedures Advisers Act Rule 206(4) and Best Practices Compliance Manual CCO Investor Eligibility - Quarterly Review of New Investor files to determine compliance with Reg D Compliance Manual CCO Books And Records - Quarterly 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 /Admin Dept. Investor Statements / Fee Calculations- Quarterly Review and verification of NAV calculations; documentation supporting calculations retained from all responsible parties. Advisers Act Section 204, Rule 204-2 Compliance Manual CFO, Admin, IR, CCO CCO - Quarterly documentation regarding the review of CCO’s email. Advisers Act Rule 204-2 Senior Mgmt. Personal Trading Certifications – Quarterly collected from access persons for their personal securities transactions. Advisors Act Rule 204A-1 Compliance Manual CCO Insider Trading/Restricted List - Quarterly Review and Maintenance of List; Verification of employee and Third Party Insider Trading compliance Compliance Manual CCO Voting- Quarterly review that proxies have been voted and records retained as required. Compliance Manual CCO/ Inv. Team ERISA Restrictions-Reporting, controls and compliance DDQ CCO/CFO
Personal Trading Reports – Monthly review of electronic system checked for personal securities transactions compliance Compliance Manual –COE CCO/ Risk Management / Investment Guidelines – Monthly Risk Committee reviews compliance with risk parameters, investment restrictions, and general portfolio assessments Compliance Manual CCO/ Risk Com Financial and/or Legal Disclosure Issues – Monthly Review for any potential occurrence of items requiring disclosure Rule 206(4)-4 Compliance Manual-COE CCO/ Senior Mgmt./ CFO/COO QUARTERLY JUNE 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 Review – Monthly email review conducted. Compliance Manual CCO/ Performance/Valuation Calculations – Monthly review for calculations and reporting accuracy. Compliance Manual CCO Personal Trading Reports – Monthly review of electronic system checked for personal securities transactions compliance Compliance Manual –COE CCO/ Risk Management / Investment Guidelines – Monthly Risk Committee reviews compliance with risk parameters, investment restrictions, and general portfolio assessments Compliance Manual CCO/ Risk Com
Investor Eligibility - Quarterly Review of New Investor files to determine compliance with Reg D Compliance Manual CCO Books And Records - Quarterly 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 /Admin Dept. Investor Statements / Fee Calculations- Quarterly Review and verification of NAV calculations; documentation supporting calculations retained from all responsible parties. Advisers Act Section 204, Rule 204-2 Compliance Manual CFO, Admin, IR, CCO CCO Email - Quarterly documentation regarding the review of CCO’s email. Advisers Act Rule 204-2 Senior Mgmt. Personal Trading Certifications – Quarterly collected from access persons for their personal securities transactions. Advisors Act Rule 204A-1 Compliance Manual CCO Insider Trading/Restricted List - Quarterly Review and Maintenance of List; Verification of employee and Third Party Insider Trading compliance Compliance Manual CCO Proxy Voting- Quarterly review that proxies have been voted and records retained as required. Compliance Manual CCO/ Inv. Team ERISA Restrictions-Reporting, controls and compliance DDQ CCO/CFO Valuations – Quarterly Valuation Committee review and assessment of specific issues related to valuations. Formal valuation of Private Assets in the Compliance Manual CCO/ Valuation Comm. Trade Allocation – Quarterly Review by Brokerage & Execution Committee and CCO to ensure compliance with allocation policies. CCO will document the review. Compliance Manual CCO/ Brokerage & Execution Com
MONTHLY Form ADV Disclosures- Review to determine whether any changes occurred at COMPANY that may require a prompt (within 30 days of amendment. CCO Email Review – Monthly email review conducted. Compliance Manual CCO/ Performance/Valuation Calculations – Monthly review for calculations and reporting accuracy. Compliance Manual CCO Personal Trading Reports – Monthly review of electronic system checked for personal securities transactions compliance Compliance Manual –COE CCO/ Risk Management / Investment Guidelines – Monthly Risk Committee reviews compliance with risk parameters, investment restrictions, and general portfolio assessments Compliance Manual CCO/ Risk Com Financial and/or Disclosure Issues – Monthly Review for any potential occurrence of items requiring disclosure Rule 206(4)-4 Compliance Manual-COE CCO/ Senior Mgmt./ CFO/COO QUARTERLY Advertising Materials - Quarterly review of compliance with advertising/sales literature policies and procedures Advisers Act Rule 206(4) and Best Practices Compliance Manual CCO Investor Eligibility - Quarterly Review of New Investor files to determine compliance with Reg D Compliance Manual CCO Books And Records - Quarterly 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 /Admin Dept. Heads
Investor Statements / Fee Calculations- Quarterly Review and verification of NAV calculations; documentation supporting calculations retained from all responsible parties. Advisers Act Section 204, Rule 204-2 Compliance Manual CFO, IR, CCO CCO - Quarterly documentation regarding the review of CCO’s email. Advisers Act Rule 204-2 Senior Mgmt. Personal Trading Certifications – Quarterly collected from access persons for personal securities transactions. Advisors Act Rule 204A-1 Compliance Manual CCO Insider Trading/Restricted List - Quarterly Review and Maintenance of List; Verification of employee and Party Insider Trading compliance Compliance Manual CCO Proxy Voting- Quarterly review that proxies have been voted and records retained as required. Compliance Manual CCO/ Inv. Team ERISA Restrictions-Reporting, controls and compliance DDQ CCO/CFO Valuations – Quarterly Valuation Committee review and assessment of specific issues related to valuations. Formal valuation of Private Assets in the Funds. Compliance Manual CCO/ Valuation Comm. Allocation – Quarterly Review by Brokerage & Execution Committee and CCO to ensure compliance with allocation policies. CCO will document the review. Compliance Manual CCO/ Brokerage & Execution Com Best Execution – Quarterly audit of securities transactions to examine factors related to Best Execution. Review and modifications to “Approved Brokers” List. Compliance Manual CCO/ Brokerage & Execution Com Errors - Quarterly Review of Trade Blotters, including Trade Errors and actions deemed necessary Advisers Act Rule 204-2 Compliance Manual CCO Soft Dollar Report – Report of all soft dollar arrangements and compliance with Section 28(e). Compliance Manual COO/CCO