Quarterly Compliance Attestation

Quarterly Compliance Attestation

Used to capture quarterly compliance attestations

press Enter

Borrowing and Loaning Money

Did you borrow money from a client (other than a relative) during the prior calendar quarter?
Did you loan money to a client (other than a relative) during the prior calendar quarter?

Communications with the Public

Did you post content for business purposes during the prior quarter that was NOT pre-approved by compliance?
This includes (but is not limited to) a website, blog, LinkedIn, or other social media platform. It does not include personal posts or content.
Include details about the platform used, the URL, handle/username, description of content posted, frequency of posts, and approximate time spent on these activities per month.

Custody – Credentials

Aside from immediate family members, have you used a client’s credentials to access a financial account?

Custody – Discretion Over Client Assets

Aside from immediate family members, have you been named to a role where you may have discretion over client assets?

Gifts

Have you reported all client gifts made during the prior quarter to compliance?
Firm policy defines a third party as any third-party supplier, vendor, client, prospective client, or other person or organization with which MAMC has a business relationship. For purposes of reporting, logo items do not constitute a “gift.” If no gifts were given, select “Not Applicable”
During the prior quarter, did you give or receive any gift in excess of a $250 market value to or from any third party as defined by MAMC policy?
Firm policy defines a third party as any third-party supplier, vendor, client, prospective client, or other person or organization with which MAMC has a business relationship. For purposes of reporting, logo items do not constitute a “gift.”

Insider Trading

As part of the business you conduct with the firm, you may be privy to information not yet available to the public. Based on this information, have you transacted any business for your or someone else’s benefit?

Marketing Activities

During the prior quarter, did you use marketing materials or engage in marketing or advertising activities without pre-approval from compliance?
Examples may include (but are not limited to): Sharing a post that advertises McLean’s (or RR’s) services, creating and using materials intended for prospective clients and clients without disclosures, encouraging someone to review McLean or RR via third-party rating services, or providing compensation for new business (ex: referrals or endorsements).

Off-Channel Communications

During the prior quarter, did you use outside communication channels to correspond with clients or with other employees regarding the firm’s business activities?
Examples of “off-channel communications” include (but are not limited to) personal email, text messages, social media, or other unsupervised communication platforms.

Personal Accounts

Have you disclosed all personal securities transactions to Compliance?
MAMC’s Code of Ethics requires that each Supervised Person disclose information related to personal securities transactions. Outside investment accounts over which you have control or beneficial ownership that can hold covered securities must be reported. This includes spouses and all dependents of the Supervised Person’s household.

Public Appearance

Have you conducted a seminar, given a media interview, or made any other public appearance that has not been pre-approved or otherwise reported to Compliance?

Publicly Traded Companies

Do you or a member of your immediate family serve in a leadership role at any publicly traded entity?

Political Contributions

During the previous quarter, did you make a political contribution to a state or city official?
­ If yes, were any made to someone you could not vote for?

Private Investing

Did you make a private securities investment away from the firm during the prior quarter, such as in a hedge fund, private placement, private company, etc.?

Protecting Client Information

­ Have you saved all files from your Downloads folder and any other local folder to Sharefile?
Have you deleted files from your hard drive and emptied your recycle bin after saving them online?
Files should be deleted from your hard drive to protect non-public information.

Regulatory Updates

Have you informed Compliance of any changes to your personal information?
This includes (but is not limited to) the following: • Professional designations • Personal residence changes • Outside business activities • Any information reported on Form U4 • Conflicts of interest

Website

During the prior quarter, did you maintain a blog or website not owned by the company?
If yes, has this already been disclosed to Compliance?

Report Compliance Concerns

Have you observed any compliance concerns you have not reported to Compliance?
You are responsible for reporting potential violations of the firm’s compliance policies or industry regulations to the CCO.

Confirmation

Do you attest that you have answered all questions accurately to the best of your knowledge?
Use Shift+Tab to go back