INVESTMENT ADVISERS
Compliance Exam Materials

III. CODE OF ETHICS

  I. Books & Records
II. Written Supervisory Procedures
III. Code of Ethics
IV. Custody
V. IA Contract Review List
VI. IA Exam Document Checklist

    A. Part 2 of Form ADV requires IAs to describe their codes of ethics to clients, and upon request, to furnish clients with a copy of the code of ethics.

    B. This disclosure will help clients understand the adviser's ethical culture and standards, how the adviser controls sensitive information and what steps it has taken to prevent employees from misusing their inside positions at client's expense.


The preceding summary has been prepared for your convenience to provide assistance in meeting the requirements for investment advisers under the Oklahoma Uniform Securities Act of 2004 (Act) and the Rules of the Oklahoma Securities Commission and the Administrator of the Department of Securities (Rules). Please note, however, that all provisions of the Act and Rules are applicable and control over this summary if there is any variance therein.