The Gifts & Gratuities Disclosure Statement serves as an important part of an investment adviser’s overall compliance program by meeting certain disclosure and reporting requirements under Rule 204A-1 of the Investment Advisers Act and section 17(e)(1) of the Investment Company  Act. The Statement allows for firms to address situations that might give rise to conflicts of interest where an adviser is presented with gifts, favors or other forms of consideration from persons doing business, or hoping to do business, with the adviser.  The statement also allows for advisory representatives and/or access persons to disclose and report all applicable gifts and/or gratuities to the firm for review and ongoing monitoring of actual and/or perceived conflicts of interest. Members also downloaded Investment Adviser Code of Ethics (COE) or Investment Adviser Rep Annual Compliance Certification.

Version/Update: V.2/September 27, 2018

Total Page Count: 1

Source/Author(s): Connexien