Compliance Review Package

206(4)(7) Review

FITS will provide the Investment Adviser with the following:

• Review portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' investment objectives, disclosures by the adviser, and applicable regulatory restrictions.
• Review trading practices, including procedures by which the adviser satisfies its best execution obligation, uses brokerage to obtain research and other services ("soft dollar arrangements"), and allocates aggregated trades among clients.
• Review trading of the adviser and personal trading activities of supervised persons.
• Review accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements.
• Review the accurate creation of required records, such as trade blotters, ADV offers and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction.
• Review the marketing RIA advisory services, including the use of solicitors.
• Processes to value client holdings and assess fees based on those valuations.
• Safeguards for the privacy protection of client records and information.
• Review Code of Ethics / Gifts and Entertainment / Privacy Policy and provide recommendations.
• Review Business Continuity and provide recommendation.
• Review any material changes to compliance policies and procedures.
• Issue final report of findings.

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