Compliance

Compliance Framework

Cavalcade Associates maintains a comprehensive compliance program designed to ensure adherence to all applicable federal and state securities laws and regulations. Our compliance framework is built on the foundation of the Investment Advisers Act of 1940 and incorporates best practices from the investment management industry.

Our Chief Compliance Officer oversees all compliance activities and reports directly to senior management to ensure the independence and effectiveness of our compliance program.

Regulatory Oversight

SEC Registration

As a registered investment advisor with the Securities and Exchange Commission (SEC), we are subject to regular examinations and must comply with comprehensive regulatory requirements including:

• Annual Form ADV updates and amendments
• Maintenance of required books and records
• Implementation of written compliance policies and procedures
• Annual compliance review and testing
• Employee training and certification requirements

State Compliance

We also comply with applicable state securities laws and regulations in jurisdictions where we conduct business, including notice filing requirements and state-specific disclosure obligations.

Code of Ethics

Our Code of Ethics establishes standards of conduct for all employees and reflects our commitment to ethical business practices. Key provisions include:

• Fiduciary duty to act in clients' best interests
• Prohibition on insider trading and material non-public information
• Personal securities trading restrictions and pre-clearance requirements
• Gift and entertainment limitations
• Confidentiality and privacy protection obligations
• Conflict of interest identification and management
• Reporting requirements for violations

All employees receive annual training on the Code of Ethics and must certify their compliance on an annual basis.

Investment Process Compliance

Suitability and Best Interest

We maintain rigorous procedures to ensure that all investment recommendations are suitable and in the best interest of our clients:

• Comprehensive client profiling and risk assessment
• Investment policy statement development and maintenance
• Regular portfolio review and rebalancing procedures
• Documentation of investment rationale and decision-making process
• Ongoing monitoring of client circumstances and objectives

Trade Allocation and Execution

Our trade allocation and execution procedures ensure fair treatment of all clients:

• Best execution policies and procedures
• Fair allocation of investment opportunities
• Aggregation and block trading when appropriate
• Trade error correction procedures
• Soft dollar and commission sharing arrangements disclosure

Risk Management

Operational Risk

We maintain comprehensive operational risk management procedures including:

• Business continuity and disaster recovery planning
• Cybersecurity and data protection measures
• Vendor due diligence and oversight
• Error and exception reporting and resolution
• Insurance coverage review and maintenance

Investment Risk

Our investment risk management framework includes:

• Portfolio risk monitoring and reporting
• Concentration and exposure limits
• Stress testing and scenario analysis
• Liquidity risk assessment
• Performance attribution and analysis

Privacy and Data Protection

We are committed to protecting client privacy and maintaining the confidentiality of personal and financial information:

• Comprehensive privacy policies and procedures
• Employee training on data protection requirements
• Secure data transmission and storage protocols
• Regular security assessments and penetration testing
• Incident response and breach notification procedures
• Vendor data protection agreements

Anti-Money Laundering (AML)

We maintain an Anti-Money Laundering program in compliance with the Bank Secrecy Act and USA PATRIOT Act:

• Customer identification and verification procedures
• Suspicious activity monitoring and reporting
• Employee training on AML requirements
• Regular program testing and review
• Designated AML compliance officer

Training and Education

We invest in ongoing training and education to ensure our team stays current with regulatory developments and industry best practices:

• Annual compliance training for all employees
• Continuing education requirements for investment professionals
• Regular updates on regulatory changes and guidance
• Industry conference participation and professional development
• Internal compliance meetings and discussions

Monitoring and Testing

Our compliance program includes regular monitoring and testing activities:

• Annual compliance review and assessment
• Periodic testing of policies and procedures
• Trade review and exception reporting
• Client communication monitoring
• Personal trading surveillance
• Expense and gift reporting review

Reporting and Documentation

We maintain comprehensive documentation and reporting procedures:

• Detailed compliance policies and procedures manual
• Regular compliance reports to management
• Incident tracking and resolution documentation
• Training records and certifications
• Regulatory correspondence and examination materials
• Client complaint logs and resolution records

Contact Our Compliance Team

If you have questions about our compliance program or need to report a compliance concern: