Compliance Policies and Procedures. To assist the Fund in complying with Rule 38a-1 of the 1940 Act, BBH&Co. represents that it has adopted written policies and procedures reasonably designed to prevent violation of the federal securities laws in fulfilling its obligations under the Agreement and that it has in place a compliance program to monitor its compliance with those policies and procedures. BBH&Co will upon request provide the Fund with information about our compliance program as mutually agreed.
Compliance Policies and Procedures. The Subadviser shall promptly provide The Vantagepoint Funds’ Chief Compliance Officer (“CCO”), upon request, copies of its policies and procedures for compliance by the Subadviser and the Fund with the Federal Securities Laws as defined in Rule 38a-1 under the 1940 Act and promptly provide the CCO with copies of any material changes to those policies and procedures. The Subadviser shall fully cooperate with the CCO as to facilitate the CCO’s performance of his/her responsibilities under Rule 38a-1 to review, evaluate and report to The Vantagepoint Funds’ Board of Directors on the operation of the Subadviser’s compliance policies and procedures and shall promptly report to the CCO any “Material Compliance Matter” as defined by Rule 38a-1(e)(2). At least annually, the Subadviser shall provide a certification to the CCO to the effect that the Subadviser has in place and has implemented policies and procedures that are reasonably designed to ensure compliance by the Fund and the Subadviser with the Federal Securities Laws.
Compliance Policies and Procedures. The Adviser shall have, in accordance with Rule 206(4)-7 under the Advisers Act, adopted and implemented written policies and procedures reasonably designed to prevent violation by the Adviser and its supervised persons of the Advisers Act and rules thereunder. The Adviser shall provide the Trust’s Chief Compliance Officer with copies of such written policies and procedures, and any amendments thereto, upon request. The Adviser shall review, at least annually, the adequacy of its written policies and procedures and the effectiveness of their implementation, and the Adviser shall provide the Trust’s Chief Compliance Officer with a summary of such annual review upon request.
Compliance Policies and Procedures. To assist the Company in complying with Rule 38a-1 of the 1940 Act, the Custodian shall provide the Company annually with the written report of an independent accountant engaged by the Custodian to conduct of an attestation examination with respect to the Custodian's internal controls over compliance which will report on the suitability of the design, at the end of a specified period, and the operating effectiveness, during the specified period, of the Custodian's controls in achieving compliance control objectives (i.e. a SOC 1 – System and Organization Controls for Service Organizations report) . The Custodian will upon request provide the Company with further information about the Custodian's compliance program in the form of responses to the Company's annual compliance review questionnaire, and otherwise as mutually agreed.
Compliance Policies and Procedures. ALPS shall, with the assistance of the Trust and the CCO and Trust counsel, review and suggest revisions to the Procedures adopted by the Trust’s Trustees and implemented by the Trust, which shall address compliance with the “Federal Securities Laws,”1 other regulatory guidance, and best practices within the industry. In addition to provisions of Federal Securities Laws that apply to the Trust, ALPS shall suggest revisions to the Procedures to address compliance with the Trust’s by-laws and all exemptive orders, no-action letters and other regulatory relief as may from time to time be received by the Trust from the Securities and Exchange Commission (the “SEC”), Financial Industry Regulatory Association, Inc. (“FINRA”), the Commodity Futures Trading Commission (“CFTC”) or any other regulatory agency or self-regulatory organization (all such items collectively, “Regulatory Relief”); provided, however, that the Procedures shall address only that Regulatory Relief afforded the Trust, Service Providers or relevant to compliance by the Service Providers or the Trust, and shall not address the terms by which other parties may receive the benefits of any Regulatory Relief. Ongoing reviews shall be completed as of a date agreed upon by the parties.
Compliance Policies and Procedures. To assist the Trust in complying with Rule 38a-1 under the 1940 Act, BBH&Co. represents that it has (i) adopted written policies and procedures that are reasonably designed to prevent, and promptly detect and correct, violations of the federal securities laws in BBH&Co.’s fulfilling its obligations under this Agreement, (ii) a compliance program in place to monitor its compliance with those policies and procedures, (iii) designate a chief compliance officer to be responsible for administering those policies and procedures, and (iv) reviewed, and periodically reviews, those policies and procedures for their continued adequacy and effectiveness. BBH&Co. further agrees that it will, annually and at such other frequency as reasonably requested by the Trust, provide to the Trust a certificate as to the continuing accuracy of the foregoing representation and such other certifications regarding BBH&Co.’s compliance program as the Trust and BBH&Co. shall mutually agree. BBH&Co. shall provide the Trust with copies of periodic reports setting forth material changes in BBH&Co.’s compliance program and shall provide such other information as the Trust may reasonably request in connection with BBH&Co.’s compliance program.
Compliance Policies and Procedures. UMBFS shall provide the Trust with quarterly and annual certifications (on a calendar basis) with respect to the design and operational effectiveness of its compliance policies and procedures ("Compliance Policies and Procedures"). UMBFS shall also provide the Trust with ongoing, direct and prompt access to UMBFS' compliance personnel and cooperate with the Trust's Chief Compliance Officer in order to provide assistance to the Trust in carrying out its obligations under Rule 38a-1 of the 1940 Act ("Rule 38a-1").
Compliance Policies and Procedures. The Custodian has adopted and implemented written policies and procedures reasonably designed to prevent the Funds from violating the Securities Act of 1933, the 1934 Act, the Sxxxxxxx-Xxxxx Act of 2002, the 1940 Act, the Investment Advisers Act of 1940, as amended, Title V of the Gxxxx-Xxxxx-Xxxxxx Act, any rules adopted by the Securities and Exchange Commission under any of these statutes, and the Bank Secrecy Act.
Compliance Policies and Procedures. KRH has Compliance Policies and Procedures that provide the workforce with clear standards of performance • KRH creates, reviews, amends and distributes policies and procedures on a regular basis for clarity, applicability to service lines and current regulations • KRH provides training on new and amended policies