A Hedge Fund Manager should regularly review and update its compliance policies and procedures and should establish internal controls to monitor compliance.

A Hedge Fund Manager should review and update its compliance policies and procedures at least annually.

A Hedge Fund Manager may conduct the review on a one-time annual review basis, on a rolling annual review basis, or other appropriate schedule to ensure that the policies and procedures remain current.  A Hedge Fund Manager should regularly monitor whether its personnel are complying with the Hedge Fund Manager’s policies and procedures through spot-checks, risk assessments, and other appropriate measures.