Annual Review
RISK ASSESSMENT AND ANNUAL REVIEW
In assessing whether the policies and procedures adopted by ADVISER in Compliance Manual and Code of Ethics adequately address ADVISER’s potential risks, ADVISER’s CCO will periodically, but no less frequently than annually, review the ADVISER’s Risk Assessment and evaluate the adequacy and effectiveness of ADVISER’s Compliance Policies and Procedures. ADVISER’s CCO may retain the assistance of third-party counsel and compliance consultants in conducting the Annual Review.
ANNUAL REVIEW CONTENTS
The CCO’s Annual Review will include specific consideration of any compliance matters that arose during the previous year; any changes in the business activities of ADVISER; and any changes to applicable laws, rules or regulations that might suggest a need to revise the Compliance Manual.
WRITTEN REPORT
Upon the conclusion of the Annual Review, ADVISER or consultants engaged by the CCO will prepare a written report. The report will contain:
The dates during which the review was conducted
Tests performed and actions taken during the review
Recommendations for actions taken to address identified risks or potential deficiencies
