INVESTMENT ADVISERS -

Annual Compliance Reviews -

All investment advisers registered with the Securities and Exchange Commission (“SEC”) or at the state level, are required to review their compliance policies and procedures at least annually (and best practice is for any investment adviser, whether SEC or state registered, or not, to engage in such a review). Many advisers with a December 31 fiscal year end traditionally conduct this review in March of each year. Regardless of when the review takes place, registered advisers should be sure to document the review process and the outcomes of the review.

Form ADV – Annual Amendment Due by March 31, 2021; Delivery of Updated ADVs to Clients -

Form ADV for registered advisers (Parts 1A, 1B (state registered advisers only) and 2A) and Exempt Reporting Advisers (relevant portions of Part 1A) with a December 31 fiscal year end must be updated by March 31, 2021 through the Investment Adviser Registration Depository (IARD) website (www.iard.com). Please be sure to select “annual amendment” when updating Form ADV in order for the filing to qualify as the annual amendment to Form ADV. Failure to update Form ADV could lead to registration or status as an Exempt Reporting Adviser being revoked...