Alaric Compliance Alaric Compliance Services, LLCServices, LLC

The Independent Compliance SolutionThe Independent Compliance Solution

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OVERVIEWOVERVIEW Alaric Compliance Services is a full-service compliance firm we

offer four primary solutions:1.1. Outsourced Chief Compliance OfficersOutsourced Chief Compliance Officers2.2. Compliance Oversight and Monitoring Compliance Oversight and Monitoring 3.3. Independent Compliance Consultations and Independent Compliance Consultations and

ExaminationsExaminations4.4. Derivatives Compliance Oversight and MonitoringDerivatives Compliance Oversight and Monitoring

The business was started in 2004 as a joint venture. In 2005 The business was started in 2004 as a joint venture. In 2005 AlaricAlaric Compliance Services, LLC was created. We are headquartered in New York City, with a regional office in Chicago.

Alaric Compliance Services has a diverse client base with assets under management ranging from $50 million to $16 billion.

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MISSIONMISSION Alaric Compliance Services Alaric Compliance Services was created to help investment advisers

and registered investment companies meet the new compliance program requirements by:

Designing, testing, and gaining senior management approval of comprehensive, written compliance policies and procedures (the implementation phase);

Providing a competent, knowledgeable individual to oversee these procedures as CCO, backed by a solid, experienced support staff (the compliance monitoring phase).

Since its founding, AlaricAlaric has become the gold standardgold standard in compliance. We hold true to our underlying mission of: Creating an independent and transparent compliance program that

is sheltered from undue influence or incentive-based structures; Implementing compliance polices and procedures that are

effective, functional and properly documented and tested for adherence.

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EXPERTISEEXPERTISE AlaricAlaric is the Nation’s leading provider of outsourced Chief Compliance Officers to a broad range of investment managers.

Alaric is also an industry leader in providing support to in-house CCOs through our comprehensive oversight and monitoring program.

QUALIFIEDQUALIFIED The Alaric TeamAlaric Team is composed of seasoned individuals, with the requisite knowledge and experience.

CUSTOMIZEDCUSTOMIZED Alaric’sAlaric’s compliance solutions are designed to satisfy your individual compliance needs in a cost effective manner.  

THE INDEPENDENT THE INDEPENDENT COMPLIANCE SOLUTIONCOMPLIANCE SOLUTION

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THE ALARIC TEAMTHE ALARIC TEAM The Alaric Team is comprised of 13 individuals, 8 professional staff

members who serve as the Chief Compliance Officer or Director of Compliance for over 20 separate entities, 1 Director of Derivatives Compliance, 1 Director of Marketing and 3 Assistant Directors of Compliance.

Adviser/Fund

Chief Compliance Officer

ALARIC’s Best Practices Committee

ALARIC’s Compliance Support Staff

ALARIC’s Regulatory Response Team

ALARIC’s Compliance Resources

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Outsourced Chief Compliance OfficersOutsourced Chief Compliance Officers AlaricAlaric provides an experienced individual to serve as CCO for your SEC-registered or unregistered advisory firm, mutual fund, hedge fund or fund of funds.

A CCO from AlaricAlaric meets the SEC's criteria for expertise, competence and authority. Moreover, an Alaric CCOAlaric CCO has the independence to assess your business practices with a clear eye and can intervene before problems turn into violations.

Our CCOs will evaluate your existing program and make recommendations to fill any gaps identified or build a new program based upon your specific requirements.

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Compliance Program Oversight and MonitoringCompliance Program Oversight and Monitoring

AlaricAlaric can provide an ongoing presence to support your in-house CCO, especially in those instances where the CCO is not a full time position or additional staff is required to fulfill the needs of your Compliance Compliance ProgramProgram.

AlaricAlaric utilizes electronic data interfaces and periodic on-site presence to perform such functions as:

Testing various compliance requirements Providing the monthly, quarterly, and annual

certifications Providing or producing back-up

documentation

These routine checks mean that we can show you are adhering to the Compliance Program. AlaricAlaric helps prove to your investors, prospects and the SEC that you take compliance seriously.

Your Alaric representative will meet regularly with management and staff to assess the control environment, conduct periodic testing, and create or modify policies in response to evolving regulations and your business needs. You will have the records you need and the processes in place to substantiate a true "culture of compliance."

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Compliance Program BuildingCompliance Program Building If you already employ a CCO and have a compliance program, Alaric’s team of Alaric’s team of professionalsprofessionals can audit your existing procedures.

Our Compliance Team can benchmark your existing practices against industry standards in order to develop robust compliance procedures that make sense in light of your particular business model.

As a result, we provide written policies and procedures that can be readily administered with testing and reporting methodologies built into each section of the compliance program.

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Derivatives Compliance Practice

Alaric has introduced a new compliance service for institutions that are active in privately negotiated OTC and central clearing system derivatives. Some of our services include:

Compliance reviews of derivatives holdings, including the development of internal policies and procedures for oversight and monitoring.

Advising clients on SEC, CFTC and self-regulatory organizations, including inspection and enforcement matters and the impact of new derivatives regulations.

Consulting clients on valuation issues relating to determining mark-to-market and termination payment calculations in illiquid or otherwise troubled markets, including in the context of distressed structured swaps.

Assisting clients in resolving disputes with their counterparties

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RISK ASSESSMENT RISK ASSESSMENT Alaric’sAlaric’s risk assessment of your firm will drive our process of

establishing a customized Compliance Program.

Specific policies and procedures are created to mitigate your operational risk. Conflicts of interest are identified and addressed.

Potential conflicts, such as side by side trading, are identified and reviews are implemented to show whether the process is fair and reasonable.

Your operating platform is reviewed to determine how to produce certain documents such as trade logs and holdings reports.

Analytical tests are created utilizing the operating platform reports to document the results.

All of the Compliance Program’s documents are captured and organized in an appropriate manner.

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CUSTOMIZED SOLUTIONCUSTOMIZED SOLUTIONBased upon your needs, through third party relationships, AlaricAlaric can

also offer automated compliance analysis, monitoring and reporting, on-

demand compliance analytics and audit trails.

Automated employee trade monitoring and pre-clearance Portfolio management process checking versus investment policy, mandate or

securities laws, or combination

Performance dispersions checking Fiduciary accounts and risk management monitoring Anti-money laundering program Best execution Fair and timely trade allocation and favoritism checking Excessive activity alerts Price/valuation: validation of process and procedures Trade suitability Account activity patterns

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COST EFFECTIVECOST EFFECTIVE According to Management Practice Inc., the highest

paid CCOs have compensation packages close to $1 million per year, and few are paid less than $150,000 annually.

The compliance solutions offered by AlaricAlaric are cost effective - youyou do not incur the cost of additional overhead, office space, technology or employee benefits.

When you hire AlaricAlaric, you hire an entire Compliance Team. That means you have a Compliance Department, not just a single CCO, and also have our expertise available 24 hours a day, 7 days a week.

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THE DIVERSITY OF OUR THE DIVERSITY OF OUR CLIENTS ENSURES BEST CLIENTS ENSURES BEST

PRACTICESPRACTICES Presently, Alaric’sAlaric’s clients have AUM ranging

from $50 million to $16 billion.     Through our diverse client base, AlaricAlaric will

leverage best practices to ensure you remain an industry compliance leader. 

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Founder and Chief Executive Officer of ALARIC Compliance Services, LLC

Mr. Talarico currently serves as the CCO to various RIC’s and RIA’s. His 22 years of experience in the financial services industry includes: Serving as the CCO to various registered advisers and mutual funds; the management of a $45 billion asset management and services group at JP Morgan-Chase; client management of SEC-registered advisers within the Institutional Custody Division of Investors Bank & Trust Company; development of an outsourced SEC regulatory compliance program for registered advisers; and legal compliance support. Just prior to founding ALARIC Compliance Services, LLC, he was the co-CEO of EOS Compliance Services, LLC. Mr. Talarico served three terms in the New Jersey State Assembly and sponsored numerous laws, including regulatory reforms in the insurance and banking industries. Mr. Talarico holds a BS ChE from Lehigh University, an MBA from Fairleigh Dickinson University and a JD from New York Law School. He is admitted to practice in New York and New Jersey.

Direct Telephone Number: 212-243-5241Email Address: gtalarico@alariccompliance.com

GUY F. GUY F. TALARICOTALARICO

Christopher LewisChristopher LewisGeneral Counsel and Director of ALARIC Compliance Services, LLC

Mr. Lewis is General Counsel and a Director of Alaric Compliance Services, LLC and has been in private practice encompassing capital markets, structured finance, derivatives, distressed assets, regulatory and international work, for over 13 years. Prior to joining Alaric, he practiced law at Brown & Wood; Simpson, Thacher & Bartlett; Simmons & Simmons (London), and, most recently, as a Partner at Thacher, Proffitt & Wood, where he was Chair of the firm's Opinion Committee and Co-Chair of the Distressed Assets Practice Group.

Mr. Lewis has served financial industry clients throughout his career. Mr. Lewis has extensive experience in derivatives, and has participated in numerous ISDA Committees, and negotiated hundreds of ISDA agreements for clients throughout his career.

Mr. Lewis has also lectured, moderated and written extensively. Mr. Lewis received his J.D. from the University of Virginia School of Law, where he was a member of the Virginia Tax Review, and his B.A. magna cum laude and Phi Beta Kappa from the College of William & Mary. He is admitted to practice law in New York and California.

Direct Telephone Number: 646-237-3486Email Address: clewis@alariccompliance.com