Develop/review/update compliance policies and procedures for the Funds, ensuring that they meet the requirements of Rule 38a-1 under the Investment Company Act of 1940 and comport with industry best practices; Conduct periodic reviews of the adequacy of the Funds' and the Service Providers' compliance policies and procedures and determine the effectiveness of their implementation; Recommend the incorporation into the Funds' compliance policies and procedures of any new or amended regulations or best practice initiatives that may be appropriate; Perform and document testing of certain key Fund and Service Provider compliance procedures, including collecting and organizing relevant compliance data and reviewing reports, investigating exceptions, and making inquiries of Fund management and the Service Providers; Conduct site visits to the Adviser and/or Sub-Advisers and other Service Providers as necessary; Meet periodically with Fund management; Prepare quarterly and annual CCO reports for the Funds' Board and attend Board meetings (in-person and telephonic); Provide other services and assistance relating to the affairs of the Funds as the Board may, from time to time, reasonably request in connection with the CCO's compliance responsibilities; Maintain records relating to the Compliance Program as required by applicable laws and regulations; Provide AML consulting and training.
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