The updated Initial/Annual Personal Securities Holdings Report serves as an important part of an investment adviser’s overall compliance program by meeting certain disclosure and reporting requirements under Rule 204A-1 and/or similar state requirements.  An adviser’s code of ethics must require a complete report of each access person's securities holdings, at the time the person becomes an access person and at least once a year thereafter. The holdings reports must be current as of a date not more than 45 days prior to the individual becoming an access person (initial report) or the date the report is submitted (annual report). Members also downloaded Investment Adviser Code of Ethics (COE) or Investment Adviser Rep Annual Compliance Certification.

Version/Update: V.3/June 18, 2024

Total Page Count: 1/.docx

Source/Author(s): Connexien