Service Description: Preparation of Legal Documents for Code of Ethics (Rule 204A-1) for a Registered Investment Adviser.
Syndicate Legal Advisory Services provides nationwide legal document preparation services for Registered Investment Advisers required to prepare a written Code of Ethics under Rule 204A-1 of the Investment Advisers Act of 1940. We prepare the Code of Ethics and related supporting materials based on the firm’s standards, procedures, and specific instructions you provide.
Documents Commonly Prepared
We prepare a full range of documents associated with a Rule 204A-1 Code of Ethics, including but not limited to:
Code of Ethics: Formatting of the written code that includes standards of business conduct reflecting the adviser’s fiduciary obligations, provisions requiring compliance with applicable federal securities laws, requirements for access persons to report personal securities holdings and transactions, procedures for review of such reports, pre-clearance requirements for initial public offerings and limited offerings, provisions for reporting violations to the Chief Compliance Officer, and requirements for distribution of the code and written acknowledgments of receipt, based on the content and descriptions you supply.
Access Person Reporting Forms: Preparation of forms for initial holdings reports, annual holdings reports, and quarterly transaction reports for access persons, based on the reporting details you provide.
Acknowledgment Forms: Formatting of written acknowledgment forms for supervised persons confirming receipt of the code and any amendments.
Related Supporting Materials: Organization of exhibits, procedures, or attachments incorporating client-supplied definitions (such as access persons or reportable securities) or other materials referenced in the code.
Updates and Amendments: Formatting of amendments to the code, based on the revised information you provide.
Documents are prepared for the firm’s internal use, distribution to supervised persons, and enforcement as required by Rule 204A-1 (subject to the information you provide). The rule requires establishment, maintenance, and enforcement of a written code of ethics meeting the specified minimum requirements, including personal securities reporting by access persons and review by the firm; clients remain fully responsible for identifying access persons, implementing and enforcing the code, reviewing reports, maintaining required records, and compliance with all Investment Advisers Act and SEC requirements.
