Attention: SEC Registered Investment Advisors

SEC approves Compliance Programs for Investment Advisers and Investment Companies.

On December 3, 2003 the SEC adopted Rule 206(4)-7 under the Investment Advisers Act of 1940 and Rule 38a-1 under the Investment Company Act of 1940. These new rules will require investment advisers and investment companies to (i) establish and implement compliance policies and procedures, (ii) annually review and update their compliance policies and procedures and (iii) designate a chief compliance officer responsible for supervising the firm's compliance with federal and state laws which govern the firm's business activities..

These new rules become effective on February 5, 2004. The mandatory compliance date for these new rules and rule amendments is October 5, 2004. On or before the compliance date, the firm must:

• designate a chief compliance officer; and
• adopt compliance policies and procedures that satisfy the requirements in the new rules.

All SEC registered Investment Advisors should review their current policies and procedures to insure they meet these new requirements. During 2004, SEC examiners will evaluate the risk management and internal control systems used by the subject advisory firm. Inspections will involve discussions with managers and compliance staff to obtain a complete understanding of the firm's control procedures in what they believe are the most critical or strategic areas. Examiners will inquire about each firm's compliance and control policies and procedures and evaluate their implementation and effectiveness.

SEC Annual Updating of Assets Filing.

SEC registered firms with the fiscal year-end of December 31st are required to file an Annual Updating Amendment through Web IARD. The deadline for this filing is March 31, 2004. The Annual Updating Amendment includes information about the firm's assets under management. The firm is required to deposit into Web IARD an annual updating fee before submission of update. See filing fee schedule below:

Please review your current business for any changes that have occurred during the past year, i.e., any new programs being offered or programs no longer being used, employee status update, or review of client base to determine if firm should notice file (or register) in additional states. The firms Form ADV should reflect current information.