Written Policies, Procedures & Internal Controls

The LeGaye Law Firm P.C., assists investment advisers in the development of effective written policies, procedures and internal controls that help prevent abuse, detect and mitigate conflicts of interest, reduce client risk and maintain compliance with client protocols and regulatory requirements. This approach helps to define the roles and responsibilities of senior management and supervisors while promoting successful business practices. To accomplish this, ongoing legal counsel and support services may include:

• Creation, review or enhancement of Written Supervisory Procedures (WSPs) or written policies and procedures manual
• Development or review of Code of Ethics manual, including personal trading processes, mistreatment of material non-public information, and counsel on internal trading surveillance programs
• Employee training on new policies and procedures
• Development of Anti-Money Laundering policies and procedures, including an annual independent audit
• Analysis of portfolio management policies and procedures, including oversight of trading activities, allocation of mixed use items for soft dollar arrangements, assessment of investment opportunities and consistency with investor goals, disclosure of best execution practices and review of best execution processes and compliance with SEC recordkeeping requirements
• Evaluation and implementation of recordkeeping and document retention policies
• Review and assessment of privacy policies and procedures regarding safeguards for protecting confidential client information
• Analysis of conflicts of interest processes
• Annual testing of policies, procedures and internal controls, with written assessment upon request

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