Investment Advisory Matters. (i) No Company Insurance Subsidiary maintains any separate account or accounts.
Investment Advisory Matters. (i) First Foundation Advisors, a Subsidiary of the Company (the “Company Investment Adviser”), is as an investment adviser under the Investment Advisers Act of 1940 (the “Investment Advisers Act”) and is currently operating, and has operated since January 1, 2021, in compliance in all material respects with all Laws and Orders applicable to it or its business and has, and is acting in compliance with, all registrations, permits, licenses, exemptions, orders and approvals required for the operation of its business or ownership of its properties and assets substantially as presently conducted. There is no investigation or audit pending or threatened in writing by any Governmental Authority, or any legal or regulatory proceeding, in each case, alleging that the Company Investment Adviser has failed to comply with applicable Law in any material respect. There is no material deficiency, violation or exception claimed or asserted in writing by any Governmental Authority with respect to any examination of the Company Investment Adviser that has not been resolved, except for a deficiency, violation or exception that would not, individually or in the aggregate, reasonably be expected to be material to the Company and its Subsidiaries, taken as a whole.
Investment Advisory Matters. (a) The Seller has adopted a formal code of ethics, a written policy regarding insider trading and othex xxxxxxxx xxx procedures required to be adopted under Rule 206(4)-7 under the Advisers Act and, with respect to such code of ethics, Rule 17j-1 under the Investment Company Act. Such code of ethics complies in all material respects with Rule 204A-1 under the Advisers Act and Rule 17j-1 under the Investment Company Act. There have been no material violations of such code of ethics, and the Seller has not received a written notice from any Governmental Authority: (i) asserting any material violation of such codes of ethics, or (ii) indicating that the Seller is under any investigation by any Governmental Authority for any alleged violation of such code of ethics. The policies and procedures of the Seller with respect to avoiding conflicts of interest, or the conflicts of interest that exist, as the case may be, are described in its most recent Form ADV (or incorporated by reference therein), as amended. As of the date of this Agreement and since the formation of the Funds, there have been no material violations of such policies.
Investment Advisory Matters. (a) The Purchaser is, or before the First Closing will be, duly registered as an investment adviser under the Investment Advisers Act and all other applicable laws. The Purchaser is, or before the Second Closing will be, duly registered as a broker-dealer under the Exchange Act and all other applicable laws.
Investment Advisory Matters. Section 4.8(a) of the Seller Disclosure Letter sets forth a list of each Relevant Company that is a registered investment adviser under the Investment Advisers Act or similar Applicable Legal Requirements (the “IA Entities”), indicating for each IA Entity the relevant investment adviser registrations held by it. Each IA Entity is, and since the Lookback Date (as required by the Investment Advisers Act or similar Applicable Legal Requirements) has been, duly registered as an investment adviser in accordance therewith. Each IA Entity has in effect, and since the Lookback Date (as required by Applicable Legal Requirements) has had in effect, compliance policies and procedures required by the Investment Advisers Act and similar Applicable Legal Requirements, and has designated and approved an appropriate chief compliance officer in accordance with Rule 206(4)-7 of the Investment Advisers Act. Copies of all such compliance policies and procedures that are in effect as of the date of this Agreement have been provided or made available to Buyer. All such compliance policies and procedures comply in all material respects with Applicable Legal Requirements, including Sections 204A and 206 of the Investment Advisers Act. The Company has provided Buyer with a copy of all SEC inspection or examination disposition letters, and each IA Entity’s response to each such letter, received or sent since the Lookback Date.
Investment Advisory Matters. (a) Each of the Adviser Entities is and since January 1, 2019 has been duly registered as an investment adviser under the Advisers Act and under all other applicable
Investment Advisory Matters. (a) The Company is duly registered as an investment adviser under the Investment Advisers Act and all applicable state and non-U.S. laws.
Investment Advisory Matters. (a) Except for the Investment Adviser with respect to the Private Funds, neither the Company nor any Company Subsidiary acts as investment adviser, general partner, managing member, sponsor, commodity pool operator or commodity trading advisor to any other pooled investment vehicle on the date hereof. The Investment Adviser does not have any investment advisory clients in the United States other than the Private Funds, does not have an investment adviser-client relationship with any investor in the Private Funds, and does not advise any investment companies that are registered or required to be registered pursuant to the U.S. Investment Company Act.
