Policies & Procedures and Code of Ethics

(aka Compliance Manual or Written Supervisory Procedures).
The Policies & Procedures (“P&P”) template helps you fulfill your supervisory responsibilities under the Investment Advisers Act of 1940 and most state securities laws.

This user-friendly tool provides sample provisions that you can customize to your own individual operating procedures and practices – while keeping you in compliance with the regulatory requirements. This is not a recitation of the law, but rather formatted as your policy document.

The sample procedures and related forms are delivered electronically in WORD for your easy customization. The document provides you with reminder prompts as to text that may need to be deleted or modified as may be applicable. Thus, with just a few easy modifications you can craft your own customized procedures that fit your operations.

Your finished product gives you an easy-to-follow policies and procedures manual to help you stay in compliance.

The P&P package includes:

• Policies & Procedures and Code of Ethics
• Compliance Calendar
• Annual Review Documentation for Policies and Procedures
• Quarterly Report of Access Persons Securities Transactions and Holding Log