1.  The Manager should have internal or external personnel with an appropriate level of accounting knowledge and experience.

1.  No applicable guidance.

2.  The Manager should have access to systems appropriate to the needs and complexities of the firm, capable of correctly recording the trading and non-trading activities of the funds from an accounting perspective. 

2.  Such systems may include:

• systems that maintain important trading-related data, including quantity, cost-basis, market-value, realized and unrealized trading gains/losses, interest and dividends, and trading-related fees and expenses;
• a general ledger that includes trading data (whether in detailed or summarized form), as well as non-trading-related data, such as management fees and expenses;
• an allocation process that allocates the fund level results to individual investors to allow for reporting at the investor level; and
• processes to ensure that all non-trading related activities are appropriately recorded from an accounting perspective, including management fees, incentive fee (or allocation) arrangements and other fees and expenses, as outlined in the fund’s organizational documents.

3.  The Manager should implement a month-end close process (or if not monthly, then at least as often as required by the fund’s organizational documents).

3.  Some processes that may be appropriate in light of the characteristics of the fund include:

• verification that any material valuation adjustment is appropriately recorded;
• verification that all non-trading-related activity is appropriately recorded;
• allocation of the fund level NAVs to individual investors; and
• preparation and distribution to investors of statements that detail their current NAV and other related financial data.

4.  The Manager should implement an annual process to produce its annual financial statements and related footnotes, which will be audited by the fund’s independent accounting firm.

4.  No applicable guidance.

5.  The Manager should implement an annual process to produce investor level tax information, as needed by investors, in accordance with the regulations promulgated by the relevant taxing authority.

5.  No applicable guidance.

6.  The Manager should periodically assess its operational controls in light of the changing needs of its business, particularly where there have been changes to the activities of the organization.

6.  No applicable guidance.