Specific Strategies. In the Specialty Finance BDC strategy, Confluence utilizes an alternating process in the trading order between discretionary accounts for which Confluence has discretion to select broker/dealers on the one hand and wrap accounts and other designated broker accounts on the other hand. Within the latter group, a random generator protocol is used to alternate the trading order among Eligible Broker/Dealers. There will be circumstances that cause a particular eligible broker/dealer to not be able to receive trade instructions in accordance with Confluence’s trade rotation which will result in such entities moving to the end of the rotation. In such circumstances, such entities can receive different and perhaps less favorable prices for their transactions than they would have had such entities been able to receive the trade instructions in the original trade rotation. Although Confluence takes reasonable steps to avoid errors, occasionally errors do occur. It is our policy that errors be identified and resolved promptly and in a manner consistent with Confluence’s fiduciary duty. Investment and operations personnel review discretionary account portfolios on a regular basis to ensure that investments are made in conformity with information regarding a client’s investment objectives provided to Confluence by the client’s Financial Advisor. Reviews are made in light of such investment objectives, applicable economic or monetary developments, overall conditions in various markets, and specific market and related developments affecting individual securities. Additionally, oversight of other investment and trading activities is provided by various Confluence committees. On a monthly or quarterly basis, the client's Custodian sends reports to clients showing transactions for the period, portfolio holdings, and performance reporting. For dual contract clients, Confluence sends quarterly portfolio appraisals that can be compared to the client statements provided by the Custodian. Investment commentary letters and additional information are periodically provided to clients. Confluence does not currently compensate third-party solicitors or engage independent contractors for client referrals. Solicitors are broadly defined as persons/firms who receive compensation for directly or indirectly soliciting clients for, or referring clients to, an investment adviser.
Specific Strategies. In the Specialty Finance BDC strategy, Confluence utilizes a rotational process to alternate the trading order between discretionary accounts for which Confluence has discretion to select broker/dealers. Within the latter group, a random generator protocol is used to alternate the trading order among Eligible Broker/Dealers. There will be circumstances that cause a particular eligible broker/dealer to not be able to receive trade instructions in accordance with Confluence’s trade rotation which will result in such entities moving to the end of the rotation. In such circumstances, such entities can receive different and perhaps less favorable prices for their transactions than they would have had such entities been able to receive the trade instructions in the original trade rotation.
