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90. Access persons not providing timely and complete transaction and holdings reports
(NA JR gets copy of statements monthly)
Our policy is have all investment statements for all access persons be available and copied to the
CCO. This eliminates the need to have the access persons providing timely transaction and holdings reports.

91. Personnel trades not in compliance with COE
Our policy is to have all personal trades approved by the CCO. If someone trades without the
CCO’s approval, that person will be reminded of the policy, and if they continue, they may have their trading
access removed.

92. Blackout periods or restricted list not adhered to
Our policy is to not have any blackout periods for employee accounts. Most employee accounts
are traded at the same time as clients through block trading which gives them no advantage. If an employee
traded a security that was also a client security, unless it was approved by the CCO, they would be reminded of the
policy and if it continued, they could have their trading access removed.

93. Review of personnel trades not timely
Our policy is to have the CCO review all employee trades. This is done daily, along with all other
trades. If the CCO does not do this in a timely manner, he will be reminded of the policy and be required to give a
reason for the delay.

98. Violations of COE not reported and dealt with
Our policy is report all violations of the COE to the CCO as soon as possible. Our policy on any
failure to report a violation may result in a review of the policy or if the violation is deserving, termination.

100. Pay to Play rules not being adhered
Our policy is to not have Pay to Play arrangements. We have no policy on not adhering to the
rules since we do not allow it.

Safeguarding Client Assets/Custody/Transmittal of Customer Funds and Securities
102. Firm taking other forms of custody (trustee, General POA, Executor)
Background
The custody rule under the Investment Advisers Act of 1940 defines custody as "holding, directly or indirectly,
client funds or securities, or having any authority to obtain possession of them." The custody definition now
includes three examples to clarify what constitutes custody for advisers as follows:
1. possession of client funds or securities, unless an adviser receives them inadvertently e.g., from a client. If the
adviser returns them within three business days of receipt, custody can be avoided (inadvertent custody);
2. any arrangement which authorizes or permits an adviser to withdraw client funds or securities, e.g., a general
power of attorney, direct debiting of advisory fees, etc.; and
3. Any capacity, e.g., general partner of a limited partnership, trustee, etc., that gives an adviser, or supervised
person, legal ownership or access to client funds or securities.

103. Not following specific custody rules including surprise examinations when required
Our policy is to not have custody of client’s assets. If we find that we have breached that rule,
our policy is that we will take all necessary steps to not have custody of the assets and review the custody rule with
the offending person.

104. Independent auditor not truly independent
We are not required to have our books independently audited.

105. Not fully disclosing on ADV documents whether the firm has custody
Our policy is to disclose that we do not have custody.