Start –Up Package Requirements

FITS will provide the Investment Adviser with the following:

Code of Ethics: Create a code of ethics, including Trading policies and procedures for registered investment adviser.

Form ADV: Complete and/or review the registered investment adviser firm's organizational structure, investment advisory activities, activities of related persons, and potential conflicts of interest

IARD Filing: Initial filing of Form ADV Parts I and II, registration of investment adviser representatives, state notice filings, etc. through the IARD/CRD systems.

Annual ADV Offering & Privacy Policy Delivery: Prepare initial Form ADV offer letter and privacy policy delivery letter to investment advisory clients.,/p>

Compliance Manual & Supervisory Procedures: RIA manual customized to specific business model.

Privacy Policy/Regulation S-P: Create a privacy policy specific to state requirements.

Disaster Recovery Plan: Recommend appropriate implementation of recovery plan specific to business model.

Investment Adviser Contract: Prepare IA Contract to execute with new advisory clients.

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