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INVESTMENT ADVISER COMPLIANCE MANUAL …

INVESTMENT ADVISER . COMPLIANCE MANUAL . AND. written supervisory PROCEDURES. April 1, 2011. CRD# 6905. SEC# 801-68779. 2100 LaSalle Plaza 800 LaSalle Avenue Minneapolis, MN 55402. Revised: 12/1/11 Page 1. TO FELTL AND COMPANY ASSOCIATED PERSONS*: As a Registered INVESTMENT ADVISER , Feltl and Company (the Firm and/or F&C ) is subject to federal and state laws and regulations governing its business of providing INVESTMENT management and advisory services to individuals and companies. These laws and regulations stem principally from the INVESTMENT Advisers Act of 1940.

Revised: 12/1/11 Page 1 INVESTMENT ADVISER COMPLIANCE MANUAL AND WRITTEN SUPERVISORY PROCEDURES April 1, 2011 CRD# 6905 SEC# 801-68779 2100 LaSalle Plaza 800 LaSalle Avenue

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Transcription of INVESTMENT ADVISER COMPLIANCE MANUAL …

1 INVESTMENT ADVISER . COMPLIANCE MANUAL . AND. written supervisory PROCEDURES. April 1, 2011. CRD# 6905. SEC# 801-68779. 2100 LaSalle Plaza 800 LaSalle Avenue Minneapolis, MN 55402. Revised: 12/1/11 Page 1. TO FELTL AND COMPANY ASSOCIATED PERSONS*: As a Registered INVESTMENT ADVISER , Feltl and Company (the Firm and/or F&C ) is subject to federal and state laws and regulations governing its business of providing INVESTMENT management and advisory services to individuals and companies. These laws and regulations stem principally from the INVESTMENT Advisers Act of 1940.

2 This INVESTMENT ADVISER COMPLIANCE and Procedures MANUAL (the IA MANUAL ) is designed to provide F&C employees with the basic rules and policies for F&C's IA business. As you go through the IA MANUAL , I hope you will find it to be a common sense source for the ground rules of our business. The IA MANUAL will be updated from time to time to reflect regulatory changes and changes in our business. Any questions you may have about the IA MANUAL should be directed to me, or to our General Counsel, Chet Taylor.

3 After you have read this MANUAL in its entirety, please sign and return to Melanie dePalma the acknowledgement that appears on the next page of this MANUAL . Sincerely, Mitchell Edwards Chief COMPLIANCE Officer *NOTE: Unless otherwise indicated, the terms Associated Person, INVESTMENT Advisor Representative (or IAR ), and Employee, may be used interchangeably in this IA MANUAL , and such terms include both employees and independent contractors who hold either the Series 65 or 66 licenses, and depending on the context, to those employees who provide sales or operational support for F&C's RIA business.

4 Revised: 12/1/11 Page 2. RECEIPT AND ACKNOWLEDGMENT. The undersigned individual acknowledges that he/she has received and read F&C's IA MANUAL , and understands the policies and procedures contained in the IA MANUAL ; and That he/she agrees to abide by these policies and procedures, including any future amendments. Name (Please Print):_____. Signature: _____. Date:_____. Revised: 12/1/11 Page 3. TABLE OF CONTENTS. SECTION 1: ORGANIZATION AND RESPONSIBILITIES. written supervisory Procedures Annual Review and Reporting F&C Internal Controls Staffing Chart Supervision supervisory Review System Qualifications of supervisory Personnel Overall Supervision Supervision of Personnel Sub-Advisers Associated Persons INVESTMENT ADVISER Representatives (IARs).

5 Dual Licensing Hiring and Registration Process Annual Personnel Review Correspondence Review E-Mail Review Disciplinary Actions SECTION 2: FILINGS AND DISCLOSURE TO CUSTOMERS / CUSTOMER AGREEMENT. INVESTMENT ADVISER (RIA) Registration and Reporting Form ADV Filing and Updating Form U-4. Disclosure to Customers Risk Disclosure Financial and Disciplinary Disclosure The Brochure Rule . The Customer Agreement Mandated by the Advisers Act of 1940 and Related Rules Other Suggested Provisions Revised: 12/1/11 Page 4.

6 SECTION 3: CUSTOMER RELATIONS; ESTABLISHING ACCOUNTS. Rules of General Conduct Recommendations Fiduciary Standard of Care Avoid Self-Dealing Consistency with Announced Strategies Follow Individual Customer Guidelines Disclosure Communication/Feedback Discretionary Accounts Contacting Prospective Customers Federal Communications Commission Cold Calling Rule Account Establishment Account Establishment Initial Review Ongoing Review SECTION 4: MANAGING CUSTOMER SERVICES. Safeguarding Customer Funds and Securities Reporting to Customers Fees General Rule Arms-Length Contract Performance Fees, Rebates, and Waivers Solicitation and Referral Fees Sales Promotions/Allowances Customer Complaints Privacy of Consumer Financial Information Voting Proxies SECTION 5: INVESTMENT AND TRADING PRACTICES.

7 In General Allocation of INVESTMENT Opportunities ERISA Customers Revised: 12/1/11 Page 5. Prohibited Transaction Exemptions Plan Fiduciary . New Safe Harbors and the Fiduciary ADVISER . Fees Prohibited Transactions Specific Types of Prohibited Transactions General Prohibitions on Self-Dealing Prohibited Transaction Exemptions Liability for Breach of ERISA Rules Proxy Voting Custody of Plan Assets Plan Asset Status Use of Model Portfolios Mutual Fund Status Sub-Advisers Supervision of Sub-Advisers Due Diligence and Pre-Qualification Agreements Monitoring ADVISER Qualifications Monitoring Portfolio Operations Reporting and Disclosure to Customers Other Securities Trading Practices

8 Selection of Brokers and Dealers Best Execution . Soft Dollar and Directed Brokerage Use of Affiliated Broker-Dealer Bunched Orders and Allocation of Trades Principal and Proprietary Transactions with Customers Agency Cross Transactions Trading by Supervised Persons Trading Errors Restrictions on Trading in Securities Use and Misuse of Research Misuse of Material Nonpublic Information Revised: 12/1/11 Page 6. Definition Examples Penalties for Misuse Personal Securities Transactions Restricting Access Restricted and Watch Lists Mergers, Tender Offers, etc Exception Reports; Investigations SECTION 6: SALES AND ADVERTISING.

9 Advertising Defined Advertising Approval Fraudulent, Deceptive or Manipulative . COMPLIANCE Review - Specific Practices Fund Prospectus and Sales Material SECTION 7: RECORDS AND SECURITY. Records Retention Requirements Journals Auxiliary Ledgers Brokerage Orders Check Books Bills and Statements Financial Statements written Communications E-Mail Retention Powers of Attorney written Agreements Circulars and Advertisements Securities Transactions by F&C and Employees Brochure Delivery, Receipt, Acknowledgment Customer Account Records Employee Records written supervisory Procedures Revised: 12/1/11 Page 7.

10 Basic Documents Security of Systems and Information Policy Access to Facilities, Electronic Systems and Data Reports and Other Communications Customer Information Corporate Policy and Procedures for Computer Security Business Continuity Plan Revised: 12/1/11 Page 8. SECTION 1: ORGANIZATION AND RESPONSIBILITIES. written supervisory Procedures Annual Review and Reporting As of October 5, 2004, new SEC Rule 206(4)-7 became effective, requiring all SEC. registered advisers to (a) adopt and implement written policies and procedures reasonably designed to prevent and detect violations of the securities laws and rules by the ADVISER and its supervised persons, (b) review no less frequently than annually the adequacy of the policies and procedures and the effectiveness of their implementation and (c).


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