Requirements related to the registration of investment advisers and the disclosure of information to clients and the public.

• Initial Registration (Section 203) - ADVS.1.1

  Advisers must register with the SEC or state authorities; unless an exemption applies.

• Annual Updating Amendment - ADVS.1.2

  Registered investment advisers must annually update their Form ADV within 90 days after fiscal year end.

• Other-Than-Annual Amendments - ADVS.1.3

  Advisers must promptly amend Form ADV if certain information becomes materially inaccurate.

• Brochure Rule - Part 2A (Firm Brochure) (Rule 204-3) - ADVS.1.4

  Advisers must prepare and deliver a written disclosure brochure (Form ADV Part 2A) to prospective and existing clients.

• Brochure Rule - Part 2B (Brochure Supplement) - ADVS.1.5

  Advisers must prepare and deliver brochure supplements for supervised persons who directly interact with clients.

• Form CRS (Relationship Summary) Delivery - ADVS.1.6

  Broker-dealers and investment advisers must deliver a relationship summary (Form CRS) to retail investors.

• Public Availability of Form ADV - ADVS.1.7

  Form ADV is publicly available through the IARD system; ensuring transparency.

Core principles governing an adviser's relationship with clients; including duties of loyalty and care.

• Duty of Loyalty - ADVS.2.1

  Advisers must act in the best interest of their clients; placing client interests before their own.

• Duty of Care - ADVS.2.2

  Advisers must exercise care and diligence in providing advice; including having a reasonable understanding of the client's financial situation and objectives.

• Best Execution - ADVS.2.3

  Advisers must seek the most favorable terms reasonably available for a client's transactions.

• Disclosure of Conflicts of Interest - ADVS.2.4

  Advisers must fully and fairly disclose all material conflicts of interest to clients.

• Client Onboarding & Due Diligence - ADVS.2.5

  Conduct reasonable diligence to understand a client's financial situation; investment objectives; and risk tolerance (Know Your Client).

• Suitability of Recommendations - ADVS.2.6

  Ensure that all investment recommendations and strategies are suitable for the client's specific circumstances.

• Client Communication & Reporting - ADVS.2.7

  Maintain regular and clear communication with clients regarding their accounts; performance; and relevant disclosures.

• Fee Disclosure and Transparency - ADVS.2.8

  Clearly disclose all fees; charges; and compensation arrangements to clients.

• Referral Fees (Rule 206(4)-3) - ADVS.2.9

  Comply with rules governing payments for client referrals.

Requirements for establishing; implementing; and maintaining a robust compliance program.

• Written Policies & Procedures - ADVS.3.1

  Develop and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act.

• Chief Compliance Officer (CCO) Designation - ADVS.3.2

  Designate a qualified Chief Compliance Officer (CCO) responsible for administering the compliance program.

• Annual Review of Compliance Program - ADVS.3.3

  Conduct an annual review of the adequacy of the compliance policies and procedures and the effectiveness of their implementation.

• Compliance Training - ADVS.3.4

  Provide ongoing training to all relevant personnel on compliance policies and procedures.

• Risk Assessment (Compliance) - ADVS.3.5

  Conduct periodic risk assessments to identify and evaluate compliance risks relevant to the firm's business activities.

• Internal Controls & Testing - ADVS.3.6

  Establish and test internal controls to ensure adherence to policies and procedures and prevent regulatory violations.

• Compliance Calendar & Monitoring - ADVS.3.7

  Maintain a compliance calendar and conduct ongoing monitoring to ensure timely completion of compliance tasks.

• Compliance Manual - ADVS.3.8

  Maintain a comprehensive compliance manual outlining all firm policies and procedures.

Specific requirements for maintaining and preserving books and records.

• Required Records Maintenance - ADVS.4.1

  Maintain all books and records required by Rule 204-2 (e.g.; journals; ledgers; order tickets; communications).

• Record Retention Periods - ADVS.4.2

  Retain records for the prescribed periods; generally five years for most records; with the first two years in an easily accessible place.

• Electronic Recordkeeping Requirements - ADVS.4.3

  Ensure electronic records are preserved in a non-rewriteable; non-erasable format (WORM) and are readily accessible.

• Accessibility of Records - ADVS.4.4

  Ensure records are readily available for examination by the SEC.

• Correspondence and Communications Retention - ADVS.4.5

  Retain all business-related written and electronic correspondence and communications with clients.

Rules governing investment advisers that have custody of client funds or securities.

• Qualified Custodian Requirement - ADVS.5.1

  Client funds and securities must be held by a qualified custodian (e.g.; banks; broker-dealers).

• Independent Public Accountant Audit (Annual) - ADVS.5.2

  For advisers with custody; obtain an annual surprise examination by an independent public accountant (unless subject to the audit provision for pooled investment vehicles).

• Delivery of Account Statements - ADVS.5.3

  Ensure clients receive account statements directly from the qualified custodian at least quarterly.

• Notification to Clients of Custody - ADVS.5.4

  Promptly notify clients in writing upon opening an account with a qualified custodian.

• Direct Fee Deduction Procedures - ADVS.5.5

  Implement specific procedures for advisers that deduct fees directly from client accounts.

• Pooled Investment Vehicle Audit - ADVS.5.6

  For certain pooled investment vehicles; obtain and distribute audited financial statements to investors.

Regulations concerning investment adviser advertising and communications with the public.

• General Prohibition on Deceptive Advertising - ADVS.6.1

  Prohibits advertisements that are false; untrue; misleading; or manipulative.

• Performance Advertising Standards - ADVS.6.2

  Ensure performance advertising is fair; balanced; and includes all required disclosures.

• Testimonials; Endorsements; and Third-Party Ratings - ADVS.6.3

  Comply with conditions for using testimonials; endorsements; and third-party ratings in advertising.

• Use of Hypothetical Performance - ADVS.6.4

  Adhere to specific requirements and disclosures when presenting hypothetical performance.

• Pre-Approval of Advertisements - ADVS.6.5

  Establish procedures for the review and pre-approval of all advertisements.

• Recordkeeping for Advertisements - ADVS.6.6

  Maintain records of all advertisements disseminated and their approvals.

• Social Media & Digital Communications - ADVS.6.7

  Implement policies and procedures for adviser use of social media and other digital communications for marketing.

Requirements for investment advisers to adopt a code of ethics.

• Adoption & Enforcement of Code of Ethics - ADVS.7.1

  Advisers must adopt and enforce a written code of ethics applicable to their supervised persons.

• Reporting of Personal Securities Transactions - ADVS.7.2

  Require access persons to report their personal securities transactions and holdings periodically.

• Pre-Clearance of Personal Securities Transactions - ADVS.7.3

  Require access persons to obtain approval before investing in certain securities.

• Prohibition on Insider Trading - ADVS.7.4

  Establish policies and procedures to prevent the misuse of material nonpublic information (insider trading).

• Reporting of Code of Ethics Violations - ADVS.7.5

  Require prompt reporting of any violations of the code of ethics to the CCO.

• Annual Acknowledgment of Code of Ethics - ADVS.7.6

  Obtain annual written acknowledgment from supervised persons that they have received and read the code of ethics.

Measures to protect client information and firm systems from unauthorized access or breaches.

• Privacy Policy Notice (Regulation S-P) - ADVS.8.1

  Provide initial and annual privacy notices to clients regarding the firm's information sharing practices.

• Safeguarding Customer Information - ADVS.8.2

  Implement administrative; technical; and physical safeguards to protect the security and confidentiality of client nonpublic personal information.

• Cybersecurity Risk Assessment - ADVS.8.3

  Conduct regular cybersecurity risk assessments to identify vulnerabilities and threats.

• Cybersecurity Policies & Procedures - ADVS.8.4

  Develop and implement comprehensive cybersecurity policies and procedures.

• Data Encryption & Access Controls - ADVS.8.5

  Implement data encryption and strict access controls for sensitive client data.

• Incident Response Plan (Cybersecurity) - ADVS.8.6

  Develop and test an incident response plan for cybersecurity breaches and data loss.

• Vendor Due Diligence (Cybersecurity) - ADVS.8.7

  Conduct due diligence on third-party vendors to assess their cybersecurity posture.

• Employee Cybersecurity Training - ADVS.8.8

  Provide regular cybersecurity awareness training to all employees.

Miscellaneous but important compliance requirements.

• Proxy Voting Policies & Procedures (Rule 206(4)-6) - ADVS.9.1

  Advisers who vote client proxies must adopt and implement policies and procedures reasonably designed to ensure voting in the client's best interest.

• Proxy Voting Disclosure - ADVS.9.2

  Disclose to clients how they can obtain information about how the adviser voted their proxies.

• Political Contributions (Rule 206(4)-5 - Pay-to-Play) - ADVS.9.3

  Comply with rules restricting political contributions to government officials or candidates who could influence the award of advisory business.

• Client Solicitation (Cash Solicitation Rule 206(4)-3) - ADVS.9.4

  Comply with conditions when paying cash referral fees to solicitors.

• Anti-Money Laundering (AML) Program (Implicit for RIAs) - ADVS.9.5

  While not explicitly under the Advisers Act; RIAs generally have AML obligations under the Bank Secrecy Act; requiring customer identification programs and suspicious activity reporting.

• Business Continuity Plan (BCP) - ADVS.9.6

  Develop; implement; and maintain a business continuity plan for unexpected disruptions.

• Supervised Persons' Outside Business Activities - ADVS.9.7

  Establish policies for supervised persons' outside business activities to identify and manage conflicts of interest.

• Form D Filings (Private Funds) - ADVS.9.8

  For advisers to private funds; comply with Regulation D filing requirements (Form D).

• Form PF Filings (Private Funds) - ADVS.9.9

  For large private fund advisers; comply with Form PF filing requirements.

• Valuation of Client Assets - ADVS.9.10

  Establish and apply consistent methodologies for valuing client assets.