Oversight of Service Providers. The CCO is responsible for overseeing, on behalf of the Fund, adherence to the written compliance policies and procedures of the Fund’s service providers, including the Fund, its investment adviser (and sub-adviser, if applicable), the distributor, the administrator, and the transfer agent (the “Service Providers”). In furtherance of this duty:
(a) The CCO shall obtain and review the written compliance policies and procedures of the Service Providers or summaries of such policies that have been drafted by someone familiar with them.
(b) The CCO shall monitor the Service Providers’ compliance with their own written compliance policies and procedures, Federal Securities Laws and the Fund’s Governing Documents and Regulatory Relief. In so doing, the CCO shall interact with representatives of the Service Providers as appropriate.
(c) The CCO shall attempt to obtain the following representations from each Service Provider and, if it fails to obtain such representations, shall report this fact to the Fund:
a. In connection with the documentation of its written policies and procedures governing the provision of its services to the relevant Fund, the Service Provider has prepared and delivered to the Fund a summary of core services that it provides to the Fund or, if no such summary is available, that it has delivered to the Fund copies of the relevant policies and procedures.
b. The Service Provider will provide to the Fund and the CCO any revisions to its written compliance policies and procedures on at least an annual basis, or more frequently in the event of a material revision.
c. The Service Provider’s written compliance policies and procedures have been reasonably designed to prevent, detect and correct violations of the applicable Federal Securities Laws and critical functions related to the services performed by Service Provider pursuant to the applicable agreement between the Service Provider and the Fund.
d. The Service Provider has established monitoring procedures, and shall review, no less frequently than annually, the adequacy and effectiveness of its written compliance policies and procedures to check that they are reasonably designed to prevent, detect and correct violations of those applicable Federal Securities Laws and critical functions related to the services performed by the Service Provider pursuant to the applicable agreement between the Service Provider and the Fund.
Oversight of Service Providers. The CCO is responsible for overseeing, on behalf of the Trust, adherence to the written compliance policies and procedures of the Trust’s Service Providers. In furtherance of this duty,
A. No later than the Effective Date, the CCO shall obtain and review the written compliance policies and procedures of the Service Providers or summaries of such policies that have been drafted by someone familiar with them.
B. The CCO shall monitor the Service Providers’ compliance with their own written compliance policies and procedures, Federal Securities Laws and the Trusts’ Indenture and Regulatory Relief. In so doing, the CCO shall interact with representatives of the Service Providers as appropriate.
Oversight of Service Providers. The CCO is responsible for overseeing, on behalf of the Trust, adherence to the written compliance policies and procedures of the Trust’s service providers, including the Trust, the advisor, the distributor, the administrator, and the transfer agent (the “Service Providers”). In furtherance of this duty,
A. No later than the Effective Date, the CCO shall obtain and review the written compliance policies and procedures of the Service Providers or summaries of such policies that have been drafted by someone familiar with them.
B. The CCO shall monitor the Service Providers’ compliance with their own written compliance policies and procedures, Federal Securities Laws and the Trusts’ Indenture and Regulatory Relief. In so doing, the CCO shall interact with representatives of the Service Providers as appropriate.
Oversight of Service Providers. The CCO is responsible for overseeing, on behalf CLIENT, adherence to the written compliance policies and procedures of CLIENT’s service providers, including CLIENT’s adviser, sub-advisers, administrator, accountant, transfer agent, custodian and principal underwriter (collectively, the “Service Providers”). In furtherance of this duty, 1 “Federal Securities Laws” are defined by the Rule as the Securities Act of 1933, the Securities Exchange Act of 1934, the Xxxxxxxx-Xxxxx Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Xxxxx-Xxxxx-Xxxxxx Act, any SEC rules adopted under any of the foregoing laws, the Bank Secrecy Act, as it applies to registered investment companies, and any rules adopted thereunder by the SEC or the Department of Treasury.
A. No later than April 17, 2009, the CCO shall obtain and review the written compliance policies and procedures of the Service Providers or summaries of such policies that have been drafted by someone familiar with them.
B. The CCO shall monitor the Service Providers’ compliance with their own written compliance policies and procedures, Federal Securities Laws and CLIENT’s Indenture and Regulatory Relief. In so doing, the CCO shall interact with representatives of the Service Providers as appropriate.
C. The CCO shall attempt to obtain the following representations from each Service Provider and, if it fails to obtain such representations, shall report this fact to CLIENT:
1. In connection with the documentation of its written policies and procedures governing the provision of its services to CLIENT, the Service Provider has prepared and delivered to CLIENT a summary of core services that it provides to CLIENT or, if no such summary is available, that it has delivered to CLIENT copies of the relevant policies and procedures.
2. The Service Provider will provide to CLIENT and the CCO any revisions to its written compliance policies and procedures on at least an annual basis, or more frequently in the event of a material revision.
3. The Service Provider’s written compliance policies and procedures have been reasonably designed to prevent, detect and correct violations of the applicable Federal Securities Laws and critical functions related to the services performed by Service Provider pursuant to the applicable agreement between the Service Provider and CLIENT.
4. The Service Provider has established monitoring procedures, and shall review, no less frequently than ann...
Oversight of Service Providers. The CCO is responsible for overseeing, on behalf of the Trust, adherence to the written compliance policies and procedures of the Trust’s service providers, including the Trust, the investment advisor, the investment sub-advisor, the administrator, and the transfer agent (the “Service Providers”). In furtherance of this duty,
A. No later than the effective date, the CCO shall obtain and review the written compliance policies and procedures of the Service Providers or summaries of such policies that have been drafted by someone familiar with them.
Oversight of Service Providers. The CCO is responsible for overseeing, on behalf of the Trust, adherence to the written compliance policies and procedures of the Trust’s service providers, including Kotak Mahindra (UK) Ltd. (“Kotak”) and distributor (the “Distributor”) (Kotak and Distributor, collectively, the “Service Providers”). In furtherance of this duty,
A. No later than , 2008, the CCO shall obtain and review the written compliance policies and procedures of the Service Providers or summaries of such policies that have been drafted by someone familiar with them.
B. The CCO shall monitor the Service Providers’ compliance with their own written compliance policies and procedures, Federal Securities Laws and the Trust’s Indenture and Regulatory Relief, Declaration of Trust and
Oversight of Service Providers. The CCO is responsible for overseeing, on behalf of the Trust, adherence to the written compliance policies and procedures of the Trust’s service providers, including the Trustee and the Trust’s sponsor (the “Sponsor”) and distributor (the “Distributor”) (the Trustee, Sponsor and Distributor, collectively, the “Service Providers”). In furtherance of this duty,
A. No later than October 5, 2004, the CCO shall obtain and review the written compliance policies and procedures of the Service Providers or summaries of such policies that have been drafted by someone familiar with them.
B. The CCO shall monitor the Service Providers’ compliance with their own written compliance policies and procedures, Federal Securities Laws and the Trusts’ Indenture and Regulatory Relief. In so doing, the CCO shall interact with representatives of the Service Providers as appropriate.
C. The CCO shall attempt to obtain the following representations from each Service Provider and, if it fails to obtain such representations, shall report this fact to the Sponsor:
1. In connection with the documentation of its written policies and procedures governing the provision of its services to the relevant Trust, the Service Provider has prepared and delivered to the Trust a summary of core services that it provides to the Trust or, if no such summary is available, that it has delivered to the Trust copies of the relevant policies and procedures.
Oversight of Service Providers. The Administrator shall maintain oversight with respect to the activities of the Service Providers and shall review all relevant reports, documentation and other work product prepared by the Service Providers, including but not limited to:
(1) Transfer agency services;
(2) Coordinate contractual relationships and communications between the Fund and its contractual Service Providers;
(3) Provide documentation regarding the current investments of the Fund and all trades executed by such investment adviser(s) as the Fund may engage from time to time (the "Adviser(s)");.
Oversight of Service Providers. Pxxxxxx has adopted an information security program that establishes adequate administrative, technical and physical safeguards to protect customer information against misuse, alteration, destruction, or unauthorized disclosure. Pxxxxxx performs due diligence on service providers and requires that all contracts with service providers, who have access to customer nonpublic personal information in the course of providing services to Prosper, have a clause that requires the provider to maintain an information security program designed to achieve these objectives. To the extent that material issues arise, risk assessments will be performed on these vendors and material issues will be monitored until resolved. Identity Theft Prevention Policy and Program The Director of Operations will perform evaluations to ensure that Prosper personnel are aware of and complying with the Program. In Pxxxxxx’s discretion, arrangements may also be made for independent third party testing to be performed. This testing will include determining if any Prosper customers have been the victims of ID theft and, if so, whether Pxxxxxx took the proper steps thereafter. In addition, such testing will focus on any modifications that should be made to the Program. In order to identify risks to covered accounts, Pxxxxxx performed an initial risk assessment taking into consideration: · The types of covered accounts Prosper offers; · The methods Prosper uses to open covered accounts; · The methods Prosper uses to provide access to Prosper customer’s accounts; and · Pxxxxxx’s experiences with identity theft. To assist us in this process, Pxxxxxx used the illustrative examples of Red Flags that are contained in Supplement A to Appendix A of the FTC’s version of the Final Rules. This information was listed on a data gathering document and distributed to the Operations Department for completion. The data gathering document required the business unit to document: · The covered account types offered by their business unit; · Controls, policies and procedures in place to comply with the provision and/or Red Flag listed for the covered accounts they offered; · The reason why a specific provision and/or Red Flag would not apply to their business unit; · The data collected (if applicable) in compliance with the provision and/or Red Flag; · What the escalation and/or decision process is and where that escalation and/or decision process is documented. Once completed, the data gathering documents were rev...
Oversight of Service Providers. The Administrator shall maintain oversight with respect to the activities of the Service Providers and shall review all relevant reports, documentation and other work product prepared by the Service Providers including but not limited to:
(1) Prepare quarterly broker security transactions summaries;
(2) Prepare monthly security transaction listings;
(3) Supply various normal and customary Fund statistical data as requested on an ongoing basis;
(4) Prepare for execution and file the Fund's federal and state tax returns;
(5) Monitor the Fund's status as a regulated investment company under Sub-chapter M of the Internal Revenue Code of 1986, as amended, and compliance with its investment objectives, policies and restrictions;
(6) Prepare and file with the SEC the Fund's annual and semi-annual shareholder reports;
(7) Prepare, coordinate with Fund's outside counsel and file with the SEC Post-Effective Amendments to the Fund's Registration Statement as needed, prepare reports to the SEC including the preparation and filing of semi-annual reports on Form N-SAR;
(8) Prepare, coordinate with Fund's outside counsel and file with the SEC notices of Annual or Special Meetings of Shareholders and Proxy materials relating to such meetings;
(9) Assist in obtaining the fidelity bond and directors' and officers' errors and omissions insurance policies for the Fund in accordance with the requirements of Rule 17g-1 and 17d-1(d)(7) under the 1940 Act as such bond and policies are approved by the Fund's Board of Directors;
