Investment Adviser Review. The review of the policies and procedures of each Fund’s investment adviser shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to:
Investment Adviser Review. The review of the policies and procedures of each Fund’s investment adviser shall cover, among other things, to the extent applicable to such Fund, policies and procedures governing and/or applicable to: (i) Portfolio management processes, including allocation of investment opportunities among clients and consistency of portfolios with clients' investment objectives, disclosures by the Fund, and applicable regulatory restrictions; (ii) Trading practices, including procedures by which the Fund satisfies its best execution obligation, uses client brokerage to obtain research and other services (“soft dollar arrangements”), and allocates aggregated trades among clients; (iii) Portfolio trading of the Fund and personal trading activities of supervised persons; (iv) The accuracy of disclosures made to investors, clients, and regulators, including account statements and advertisements; (v) Safeguarding of client assets from conversion or inappropriate use by advisory personnel; (vi) The accurate creation of required records and their maintenance in a manner that secures them from unauthorized alteration or use and protects them from untimely destruction; (vii) Marketing of advisory services, including the use of solicitors; (viii) Processes to value client holdings and assess fees based on those valuations; (ix) Safeguards for the privacy protection of client records and information; and (x) Business continuity plans. It is understood that the chief compliance officer of each Fund’s investment
