ACA Compliance Group E-Coffeehouse

Copy of annual questionnaire

Kathy Dunne — Wed, 12 Nov 2008 19:15:58 GMT

I would like a copy of your annual questionnaire.

thank you

Forum: Compliance Risks Associated With Fixed Income Securities

Counterparty Reports

ACA Webcast Attendee — Wed, 12 Nov 2008 19:13:34 GMT

Are these counterparty reports used for fixed income, or just derivatives?

Forum: Compliance Risks Associated With Fixed Income Securities

Net Gains

ACA Webcast Attendee — Wed, 12 Nov 2008 18:54:45 GMT

If a net gain occurs at the end of the year, can the manager keep that gain?

Forum: Compliance Risks Associated With Fixed Income Securities

Overriding a 3rd Party Pricing Service

ACA Webcast Attendee — Wed, 12 Nov 2008 18:53:45 GMT

In these dynamic credit markets the security price moves all over the place. How can a RIA be expected to override a reputable 3rd party pricing service?

Forum: Compliance Risks Associated With Fixed Income Securities

Adjustment to the NAV

ACA Webcast Attendee — Wed, 12 Nov 2008 18:52:03 GMT

Do you make any adjustment to the NAV?

Forum: Compliance Risks Associated With Fixed Income Securities

Notify Client of Gain

ACA Webcast Attendee — Wed, 12 Nov 2008 18:51:19 GMT

Do we have to notify the client if they've benefited from a gain?

Forum: Compliance Risks Associated With Fixed Income Securities

"Free Research"

ACA Webcast Attendee — Wed, 12 Nov 2008 18:50:32 GMT

We received "free research" from a number of broker/dealers which we rely on in our research process. We do not participate in any soft dollar arrangements. Is this acceptable under 28(e)?

Forum: Compliance Risks Associated With Fixed Income Securities

Quoted Index Price vs. Realizable Value of Assets

ACA Webcast Attendee — Wed, 12 Nov 2008 18:48:56 GMT

Given the situation of the credit markets, do port managers experience divergences between the quoted indexed price for debt sec. as used for NAV calculation purposes and the realizable value of these assets when clients are required to redeem? If so how?

Forum: Compliance Risks Associated With Fixed Income Securities

Sufficient for Best-Ex

ACA Webcast Attendee — Wed, 12 Nov 2008 18:47:14 GMT

In terms of best execution, if our firm typically uses 2 custodians for the majority of our clients and chooses the one who provides the better bid, is that sufficient for best-ex purposes? We typically do not have much fixed income.

Forum: Compliance Risks Associated With Fixed Income Securities

Certifying Compliance with Fed Sec Laws: 38a-1

ACA Webcast Attendee — Tue, 21 Oct 2008 18:14:51 GMT

Please comment on a request to a fund sub-adviser to certify compliance with the Federal Securities Laws, as defined by 38a-1. My point--206(4)-7 only requires a sub-adviser to have policies and procedures designed to satisfy the Investment Advisers Act.

Forum: Providing Fund Attestations: What This Means to Advisers

Time Stamp for Mutual Funds

ACA Webcast Attendee — Tue, 21 Oct 2008 18:13:25 GMT

You mentioned a Time Stamp is required for trades for a Mutual Fund. We are a sub-advisor to a mutual fund and we have trade discretion. We use Moxy Trade Order Management Software. All trades are entered into Moxy. Does this meet the requirement?

Forum: Providing Fund Attestations: What This Means to Advisers

CCO overreaching sub-attestation requests

ACA Webcast Attendee — Tue, 21 Oct 2008 18:12:21 GMT

Nick and Erica: can you give me an example of a CCO overreaching with their sub-attestation requests?

Forum: Providing Fund Attestations: What This Means to Advisers

Privacy - Regulation S-P

C. Church — Thur, 09 Oct 2008 22:17:09 GMT

Can anyone please advise if Regulation S-P extends to investors of offshore funds ? Thanks - CDC

Forum: Marketing Series #2 Traditional Investment Advisers

Per-fee and Fixed-fee

ACA Webcast Attendee — Tue, 23 Sep 2008 18:49:18 GMT

In situations where we have both per-fee and fixed-fee accounts for a particular investment strategy, when we are presenting net of fee model performance do we have to track what's actually higher in the performance period presented?

Forum: Adherence to GIPS and SEC Rules When Marketing

Portability

ACA Webcast Attendee — Tue, 23 Sep 2008 18:47:58 GMT

What if a group moves from one corporate subsidiary to another, what happens with portability then?

Forum: Adherence to GIPS and SEC Rules When Marketing