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Portfolio Management 51
Investment Processes 52
Procedure 52

Investment Processes, Inverse and Leveraged ETFs 53
Due Diligence 53
Pre Purchase Client Suitability 53
Post Purchase Client Suitability 53
Inverse ETF Education 53
Reviews of Inverse ETF positions 54

Mutual Fund Share Class Selection Policy 54

Trading Practices 54
Aggregation 54
Allocation 54
IPOs 55
Trade Errors 55
Procedure 55
Research Processes 55
Allocation of Aggregated Trades Among Clients 55

Block Trading 56

Proprietary Trading of the Adviser and Personal Trading Activities of Supervised Person 57
Proprietary Trading 57
Investing Personal Money in the Same Securities as Clients 57
Trading Securities At/Around the Same Time as Clients’ Securities 57

Best Execution 57

Principal Trading 58

Performance 59
Procedure 59

Safeguarding of Client Assets From Conversion or Inappropriate use By Advisory Personnel 60

Proxy Voting 61

Accuracy of Disclosures Made to Investors, Clients, and Regulators 62
Account Statements 62
Advertisements 62
Solicitors 62

Directed Brokerage 63

Agency Cross Transactions 64

IARs Selling Away and Limits on Their Activities 65

Wrap Fee Adviser 66

Wrap Fee Sponsor 67

Supervision & Internal Controls 68
Form ADV (Part 2A and 2B) & Update Procedures 68
ADV PART 2A Firm Brochure 68
Procedure 69

ADV PART 2B Firm Brochure Supplement 69

ADV Update Requirements 69

Distribution of Disclosure Document 70
ADV PART 2A Firm Brochure 70
ADV PART 2B Firm Brochure Supplement 70
Distribution Requirements 71

Form CRS 72