Books and Records

Section 3(a)(37) of the Exchange Act broadly defines “records” as “accounts, correspondence, memorandums, tapes, discs, papers, books, and other documents or transcribed information of any type, whether expressed in ordinary or machine language.”

Rule 204-2 of the Advisers Act sets forth the specific categories of books and records that Fund Managers must maintain in true, accurate and current form. Any communication, written or electronic, sent or received pertaining to any of the categories of “records” set forth in Rule 204-2 must be maintained for recordkeeping purposes.

The TurboCompliance^® books and records compliance module provides the ability to automate the monitoring, supervision, detecting, reporting, documenting, sanctioning, annual review and forensic testing driven by your compliance procedures.

Within our books and records compliance section we provide a thorough discussion of how we work in concert with your CCO, attorney and CPA to build a version of TurboCompliance which delivers an absolute culture of compliance.

Since this section provides sample compliance procedure language, you must register for a TurboDoc Share Account in order to obtain access; please click here to request access.

In this section we provide a compliance practice guide which addresses:

• Organization Documents
• Personnel Records
• Written Communications and Notes
• Advertising Materials
• One to One Presentations
• Disclosure Statements
• Privacy Notices
• Soft Dollars
• Best Execution
• Personal Securities Trading
• Client/Investor Account Documentation and Records, e.g., forms, agreements, transaction records, discretionary power and other required documentation
• Comprehensive Document Management Platform which automatically maintains and archives your
  • Written Supervisory Procedures
  • Ethics Code & Insider Trading Policy
  • Anti-Money Laundering Policy
  • Business Continuity Plan
  • Accounting Records