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● Form ADV Distribution Records: The firm’s CCO must keep a record of providing all new clients the ADV
Form 2 brochures. This is recorded in the client contract. The firm’s CCO must keep record of the annual
distribution, if required, to all existing clients of the most recent ADV or brochure.
● Advertising Records: Any time the firm runs an advertisement, sends a newsletter, publishes an article, or
does anything that could be considered to be an advertisement, promotion, or marketing campaign, the
firm’s CCO must keep a copy of it and a record of to whom it was sent. (Note: most states require
documents that at sent to 2 or more individuals be maintained, the SEC requires documents that are sent
to 10 or more to be maintained.) All advertising, is stored electronically in CIS’s Dropbox.
● Soft-Dollar Arrangement Records: See the Soft-Dollar Section of this Manual, all records relating to soft
dollar arrangement will be kept in compliance with policies and procedures.
● Financial Bookkeeping Records: The firm’s CCO, or designated principal, must monitor the firm’s financial
books and records and assure that the responsible party is maintaining the required documents and
records and that they are current and up to date.