Investor Representative Services

Available from Arthur Bell, Certified Public Accountants

Compliance with Section 206(3) of the Investment Advisers Act of 1940 requires advisers to disclose the principal or agency transaction in writing to its applicable clients. Arthur Bell helps by acting as the investor representative on behalf of the adviser’s clients. We are responsible for receiving written notification of the principal or agency transaction and then providing consent to the transaction. Advisers appreciate having Arthur Bell as its main point of contact. We also assist advisers with educating their traders and internal staff about what is needed to ensure compliance.

Once we gain the approval of the clients to serve as the investor representative, we are able to:
• Provide timely consent to principal or agency transactions after we first:
- Understand the business purpose of the transaction
- Determine if there is any compensation paid to the adviser as a result of the transaction
- Identify all conflicts of interest and develop procedures to mitigate those conflicts of interest
- Assistance with ensuring there is appropriate third party evidence supporting that the transaction is occurring at a price that is indicative of fair value
- Prepare thorough documentation that meets regulatory guidelines
- Perform any additional procedures deemed necessary
• Consult on compliance with regulations
• Share best practices in the industry
• Possibly eliminate commissions charged by executing brokers

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