| ACA Compliance | ALPS Fund | Atlantic Fund | BNY Mellon | Citi | J.P. Morgan | Merrill Corp. | |
| STAFFING PROFILE | |||||||
| Compliance Personnel | |||||||
| Average industry experience (in years) | 20 | 18 | 22 | 25-30 | 23 | 15-20 | 20-25 |
| Average tenure of compliance staff (in years) | 8 | 7 | 16 | 13 | 21 | 5 | 15 |
| Primary client contact and R/C staff at same location | Y | Y | Y | Y | Y | Y | N/A |
| Quality incentives available | Y | Y | Y | Y | Y | Y | N/A |
| Attorneys have SEC filing and '40 Act experience | ** | Y | Y | Y | Y | Y | Y |
| Internal attorneys | ** | Y | Y | Y | Y | Y | Y |
| # of documents filed with SEC annually | 1,900 | 100+ | 250-300 | ** | 500+ | ** | 50,000+ |
| Former SEC regulators/ examiners on staff | Y | Y | N | Y | N | N | N/A |
| Former FINRA regulators/ examiners on staff | Y | N | N | N | N | N | N/A |
| Former CCOs on staff | Y | Y | Y | Y | Y | N | N/A |
| Dedicated training staff/ curriculum for comp. employees | Y | Y | Y | Y | N | Y | N/A |
| % of dedicated training staff/ curriculum for comp. employees | ** | 20 | ** | ** | N/A | ** | N/A |
| Level of compliance employee turnover | 0 | 10 | 20 | ** | 0 | ** | N/A |
| BUSINESS ESSENTIALS | |||||||
| % of staff with specialized designations | ** | 10 | 50 | ** | 20 | ** | N/A |
| # offices outside of the US | 1 | 0 | 0 | 83 | 0 | 11 | 15 |
| # offices in Europe | 1 | 0 | 0 | 26 | 0 | 5 | 3 |
| # offices in North America (Non-US) | 0 | 0 | 0 | 17 | 2 | 0 | 2 |
| Northern Lights | Northern Trust | NRS | Ultimus | UMB Fund | U.S. Bancorp | ||
| STAFFING PROFILE | |||||||
| Compliance Personnel | |||||||
| Average industry experience (in years) | 22.1 | 9 | 20+ | 17 | 19 | 17 | |
| Average tenure of compliance staff (in years) | 7.9 | 4 | 10+ | 5 | 15 | 16 | |
| Primary client contact and R/C staff at same location | Y | Y | N | Y | Y | Y | |
| Quality incentives available | Y | Y | Y | Y | Y | Y | |
| Attorneys have SEC filing and '40 Act experience | Y | Y | Y | Y | Y | Y | |
| Internal attorneys | Y | Y | Y | Y | Y | Y | |
| # of documents filed with SEC annually | 0 | 350-400 | 100+ | ** | 500+ | 3,304 | |
| Former SEC regulators/ examiners on staff | N | N | N | Y | N | N | |
| Former FINRA regulators/ examiners on staff | Y | N | Y | N | N | N | |
| Former CCOs on staff | N | Y | Y | Y | N | Y | |
| Dedicated training staff/ curriculum for comp. employees | N | N | N | Y | N | Y | |
| % of dedicated training staff/ curriculum for comp. employees | N/A | N/A | N/A | 5 | N/A | N/A | |
| Level of compliance employee turnover | 10 | 0 | <10 | 8 | 9 | 9 | |
| BUSINESS ESSENTIALS | |||||||
| % of staff with specialized designations | 38 | 59 | 50 | 20 | ** | 12 | |
| # offices outside of the US | 0 | 19 | 0 | 0 | 0 | 3 | |
| # offices in Europe | 0 | 8 | 0 | 0 | 0 | 2 | |
| # offices in North America (Non-US) | 0 | 1 | 0 | 0 | 0 | 0 | |
** Not reported
N/A Not Applicable