Fund Administrator, Fund Accounting and Fund Transfer Agent Review. The review of the policies and procedures of each Fund’s administrator, fund accountant and transfer agent shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to:
Fund Administrator, Fund Accounting and Fund Transfer Agent Review. The review of the policies and procedures of each Fund’s administrator, fund accountant and transfer agent shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to: (i) Maintenance of Fund records including board materials and correspondence with regulators; (ii) Portfolio trading of the Fund and personal trading activities of supervised persons; (iii) Processes to ensure timely filing of Fund reports; (iv) Auditors comments noted in SSAE 18 reports; (v) The prevention of money laundering; and (vi) Business continuity plans. In conducting its review of the policies and procedures of the Trust’s Service Providers, as they relate to the Trust’s compliance with the Federal Securities Laws, NLCS may rely on summaries, reviews or statements prepared by the chief compliance officers of a Service Provider or a third party. Each Service Provider is responsible for proper development and implementation of its policies and procedures. Although NLCS performs a review of each Service Provider’s policies and procedures, NLCS cannot ensure that all necessary policies are adopted and implemented by such Service Provider.
