COMPLIANCE ON-SITE REVIEW QUESTIONNAIRE Compliance On-site Exam Questionnaire - IAR Step 1 of 13 7% Redhawk Investment Advisor Representative Name* First Last Additional Redhawk Investment Advisor Representative Name (if applicable) First Last Additional Redhawk Investment Advisor Representative Name (if applicable) First Last Additional Redhawk Investment Advisor Representative Name (if applicable) First Last Additional Redhawk Investment Advisor Representative Name (if applicable) First Last Date* MM slash DD slash YYYY What is your DBA (doing business as) name?*Address* Street Address Address Line 2 City State / Province / Region ZIP / Postal Code AfghanistanAlbaniaAlgeriaAmerican SamoaAndorraAngolaAnguillaAntarcticaAntigua and BarbudaArgentinaArmeniaArubaAustraliaAustriaAzerbaijanBahamasBahrainBangladeshBarbadosBelarusBelgiumBelizeBeninBermudaBhutanBoliviaBonaire, Sint Eustatius and SabaBosnia and HerzegovinaBotswanaBouvet IslandBrazilBritish Indian Ocean TerritoryBrunei DarussalamBulgariaBurkina FasoBurundiCabo VerdeCambodiaCameroonCanadaCayman IslandsCentral African RepublicChadChileChinaChristmas IslandCocos IslandsColombiaComorosCongoCongo, Democratic Republic of theCook IslandsCosta RicaCroatiaCubaCuraçaoCyprusCzechiaCôte d'IvoireDenmarkDjiboutiDominicaDominican RepublicEcuadorEgyptEl SalvadorEquatorial GuineaEritreaEstoniaEswatiniEthiopiaFalkland IslandsFaroe IslandsFijiFinlandFranceFrench GuianaFrench PolynesiaFrench Southern TerritoriesGabonGambiaGeorgiaGermanyGhanaGibraltarGreeceGreenlandGrenadaGuadeloupeGuamGuatemalaGuernseyGuineaGuinea-BissauGuyanaHaitiHeard Island and McDonald IslandsHoly SeeHondurasHong KongHungaryIcelandIndiaIndonesiaIranIraqIrelandIsle of ManIsraelItalyJamaicaJapanJerseyJordanKazakhstanKenyaKiribatiKorea, Democratic People's Republic ofKorea, Republic ofKuwaitKyrgyzstanLao People's Democratic RepublicLatviaLebanonLesothoLiberiaLibyaLiechtensteinLithuaniaLuxembourgMacaoMadagascarMalawiMalaysiaMaldivesMaliMaltaMarshall IslandsMartiniqueMauritaniaMauritiusMayotteMexicoMicronesiaMoldovaMonacoMongoliaMontenegroMontserratMoroccoMozambiqueMyanmarNamibiaNauruNepalNetherlandsNew CaledoniaNew ZealandNicaraguaNigerNigeriaNiueNorfolk IslandNorth MacedoniaNorthern Mariana IslandsNorwayOmanPakistanPalauPalestine, State ofPanamaPapua New GuineaParaguayPeruPhilippinesPitcairnPolandPortugalPuerto RicoQatarRomaniaRussian FederationRwandaRéunionSaint BarthélemySaint Helena, Ascension and Tristan da CunhaSaint Kitts and NevisSaint LuciaSaint MartinSaint Pierre and MiquelonSaint Vincent and the GrenadinesSamoaSan MarinoSao Tome and PrincipeSaudi ArabiaSenegalSerbiaSeychellesSierra LeoneSingaporeSint MaartenSlovakiaSloveniaSolomon IslandsSomaliaSouth AfricaSouth Georgia and the South Sandwich IslandsSouth SudanSpainSri LankaSudanSurinameSvalbard and Jan MayenSwedenSwitzerlandSyria Arab RepublicTaiwanTajikistanTanzania, the United Republic ofThailandTimor-LesteTogoTokelauTongaTrinidad and TobagoTunisiaTurkmenistanTurks and Caicos IslandsTuvaluTürkiyeUS Minor Outlying IslandsUgandaUkraineUnited Arab EmiratesUnited KingdomUnited StatesUruguayUzbekistanVanuatuVenezuelaViet NamVirgin Islands, BritishVirgin Islands, U.S.Wallis and FutunaWestern SaharaYemenZambiaZimbabweÅland Islands Country Please enter any firm website addresses.*Enter N/A if none.What year was your firm founded?*What services do you provide?*Please explain your experience, active licenses, and active designations.*Including yourself and all other advisors named above, how many people are on your staff?*Total AUM*Managed/RGP (formerly RUMA) AUM*OIP (Open Investment Platform) AUM*Enter N/A if none.Non-managed/Legacy AUM*Enter N/A if none.Structured Notes*Enter N/A if none.FIAs*Enter N/A if none.How many financial plans have you written in the last 12 months?*OtherNumber of accounts*Do you have any comments you'd like to add?1. Firm InformationHave there been any changes to ownership structure? If so, please notify Redhawk's CCO immediately.* Yes No Please provide an updated organizational chart.Max. file size: 128 MB.Have there been any changes to number of employees, descriptions, and biographies of partners, key personnel, portfolio managers, directors, and officers?* Yes No Please include information for any of the aforementioned if they serve as officers, directors, or on creditors’ committees.*Do you stay current on regulatory/industry changes?* Yes No How?*Why not?*In the last 12 months, have there been any employees disciplined and/or terminated?* Yes No Please provide the reason for the action.*Has there been any changes to the firm’s committees, responsibilities, and/or members?* Yes No Please describe in detail the changes.*Do you have any comments you'd like to add?1A. Background Check/Entity and Litigation/RegulatoryAre there any outstanding litigation, court actions (e.g. bankruptcy, liens (tax and otherwise), foreclosure, or any entity related issues (corporate filings) initiated during the past 36 months not previously reported to Redhawk?*This includes any affiliate company or partnership that any principal, portfolio manager and/or C-Level Officer is involved with that is affiliated with the Advisor. Please provide full details. Yes No Please attach a copy of any relevant documentation.This includes any affiliate company or partnership that any principal, portfolio manager and/or C-Level Officer is involved with that is affiliated with the Advisor. Please provide full details.Max. file size: 128 MB.Are there any litigation or other court action noted above concluded within the past 36 months?*This includes any affiliate company or partnership that any principal, portfolio manager and/or C-Level Officer is involved with that is affiliated with the Advisor. Please provide full details. Yes No Please attach a copy of the results.This includes any affiliate company or partnership that any principal, portfolio manager and/or C-Level Officer is involved with that is affiliated with the Advisor. Please provide full details.Max. file size: 128 MB.For any matter not previously disclosed, has there been any examination, enforcement action, and/or investigation by the SEC, FINRA, NFA, CFTC, and/or any similar state or other domestic USA and/or international governmental body, agency, or department thereof, of or against you, its principals, its executive officers, or their affiliates (whether affiliated with you or not) (hereafter jointly referred to as “Parties”), or any other mutual fund or pooled investment vehicle managed by the Parties during the past seven (7) years?* Yes No For those matters still pending, discuss and provide copies of all correspondence between the Parties and the regulator. For those matters concluded, discuss and provide a copy of any deficiency or comment letter along with the Parties’ response thereto, and any administrative Order and/or Settlement or other resolution. In addition, if applicable, discuss any improvements made to your compliance procedures or systems as a result of any examination, investigation and/or enforcement action or recommendations made by the regulator. Further, if applicable, include copies of any administrative and/or civil and/or criminal pleadings and any related Orders resulting from the examination, investigation and/or enforcement action against any Parties.Max. file size: 128 MB.Have you had a regulatory exam?* Yes No What was the date of your last regulatory exam? (Provide the date and regulatory body conducting the exam.)*Do you have any comments you'd like to add?1B. ComplaintsDo you have a complaint file?* Yes No Have you received any customer complaints since Redhawk's last site visit?*This includes any principal, portfolio manager, and/or indirect Officer that has any complaint arising out of their affiliate company or partnership (if applicable). Yes No If yes, please provide complete details.Do you send all customer complaints to Redhawk in a timely manner (within 7 days)?* Yes No Do you have any comments you'd like to add?1C. ConflictsDo you have an affiliated Broker-Dealer?* Yes No Do you trade through the affiliate for any transaction?*If yes, this must be disclosed on ADV. Yes No Do you inform clients referred from an affiliated Broker-Dealer of corresponding conflicts?* Yes No If yes, how?If no, why not?Do all clients pay the same commission rate for affiliated Broker-Dealer transactions?* Yes No Has there been any payment of commissions or other fees to any affiliate on non-traded investments?* Yes No Please provide transaction information.*Information containing any commissions or other fees paid to you.Does the fund have a 12b-1 fee?* Yes No Do you receive 12b-1 fees?* Yes No Is supporting documentation maintained?* Yes No Do you have Separately Managed Account (SMA) clients?* Yes No Do any other principal and/or partner have clients investing alongside a sub-advised fund?* Yes No Can you demonstrate that the SMAs or the fund is not being disadvantaged?* Yes No Has this relationship been previously disclosed to Redhawk?* Yes No Do you have any comments you'd like to add? 2. Best ExecutionAre you approved for Redhawk's Open Investment Platform (OIP)?* Yes Yes, but I only have clients on the Held-Away Open Investment Platform (HOIP) No How do you monitor best execution?*How often do you review best execution?*Required annually. At least quarterly for best practice. Large Broker-Dealers should be able to provide best execution reports to you for documentation purposes.Do you use foreign equity securities not listed on a domestic exchange as part of their portfolio?* Yes No Do you use any “mark-up” in addition to the stated commission in its determination of best execution? Please explain.* Yes No Do you have any comments you'd like to add? 3. Soft Dollar ArrangementsAre there any soft dollar arrangements?*Soft dollars include any dollars retained on a trade to be used for services for the client's benefit. Yes No Are the soft dollar arrangements in compliance with Redhawk's Compliance Manual?*E.g. software is permitted but hardware is not; Bloomberg service is permitted but the terminals are not Yes No Does a third-party assist you in determining the soft dollar expenditures?* Yes No Please explain.*Are soft dollars directed to a third-party?*E.g. not through you Yes No Please explain the soft dollar flow for paying soft dollars.*Do you have any comments you'd like to add? 4. Trade Allocation/BunchingDo you have a written policy on trade execution?* Yes No Please attach a document that explains your trade execution.*Max. file size: 128 MB.Why not?*Do you allocate trades among clients and sub-advised funds?* Yes No What is the method of allocation?*Avg. price/costs, pro-rata, etc.Do you allow directed trades?* Yes No Please explain.*Do you have any comments you'd like to add? 5. Portfolio ComplianceDo you have clients on Redhawk's Open Investment Platform (OIP)?* Yes Yes, but I only have clients on the Held-Away Open Investment Platform (HOIP) No 5A. Pre & Post-Trade ComplianceDo you have a pre-trade checklist or compliance system?* Yes No Is it used, documented, and reviewed?* Yes No Do you have a post-trade checklist or compliance system?* Yes No Is it used, documented, and reviewed?* Yes No Do you have any comments you'd like to add?5B. Portfolio ManagementDo you use leverage in the portfolios?*Defined as margin. Yes No Do you use short positions in the portfolio?* Yes No Do you allow portfolio lending?*Defined as borrowing money from a lender and using portfolio securities as collateral to purchase securities. Yes No How do you test to find/prevent portfolio manipulation and how often is it done?*Suggest quarterly testDid you conduct due diligence (initial and ongoing) on the product and the manager?* Yes No Please provide details of due diligence on the product and the manager.*Does the portfolio(s) use alternative investments as part of its strategy?*e.g. invests in hedge funds, private equity, non-traded REITS. Yes No Did you appropriately account for the risks of this type of investment in your risk assessment?* Yes No How are the risks mitigated?*Do you have trade reconciliation procedures?* Yes No What is the frequency?*Why not?*Do you monitor portfolio turnover rate?* Yes No Please explain.*Why not?*Have there been any trade errors in the last 12 months?* Yes No Was the client made whole in a timely manner?* Yes No Are corrective actions documented?* Yes No Who places the trades?*Do you review trades for exceptions?* Yes No How often?*Do you have an order management and/or other trading systems to assist in tracking commissions, setting up trading rules, and creating an audit trail around the execution lifecycle?* Yes No Please explain.*Does the portfolio have any fixed income securities?* Yes No Please list the types of fixed income securities you are using.*Do you conduct stress testing?* Yes No What type of testing do you conduct?*How is this documented?*Do you have any comments you'd like to add?5C. CustodyDo you have custody of client funds or securities other than to debit client accounts for management fees?* Yes No Did you alert Redhawk as to the fact that you have custody of client funds?* Yes No Please attach any relevant information.Max. file size: 128 MB.Have you inadvertently received cash or securities?* Yes No What procedures do you have in place to address this?*Does the portfolio contain mutual funds that pay a 12b-1 fee?* Yes No Who receives the 12b-1 fee?*Do you have any comments you'd like to add?5D. Valuation/PricingDoes the portfolio have any securities that are being fair valued?*Not automatically valued through an exchange. Yes No What is the process and are the logic and details for the fair valuation documented?*Does your portfolio have fixed income securities?* Yes No How do you validate prices?*Does a third-party value your fixed income portfolio?* Yes No Who is the third-party?*Explain the process for ongoing monitoring of the third-party’s valuation policies and procedures.*Have you ever challenged the pricing?* Yes No Please provide details.*Do you have any comments you'd like to add? 6. Code of EthicsAre all code exceptions/violations reported to Redhawk's CCO?* Yes No Were there any reported in the past 12 months?* Yes No Does every new employee sign-off on reading the Code of Ethics within 10 days of employment?* Yes No Is there an annual sign-off on reading the Code of Ethics by all employees?* Yes No Do you have duplicate brokerage account statements of your personal accounts sent to Redhawk’s CCO?*If not, please send the most recent statement(s) for your personal account(s) to Redhawk Compliance and set up duplicate statements to be sent to Redhawk at: 7700 France Ave. S. Suite 430, Minneapolis, MN 55435. Yes No Do you pre-clear personal trades on the Restricted Securities List with Redhawk’s CCO?* Yes No Do you pre-clear all Outside Business Activities, including board participation, with Redhawk’s CCO?* Yes No Do you disclose all political contributions (monetary or volunteerism) to Redhawk’s CCO?* Yes No Do you have any comments you'd like to add? 7. Compliance ManualWhat is the date of the last Compliance Manual you received?* MM slash DD slash YYYY Do you require all employees to read and fully understand the information contained in the Compliance Manual?* Yes No Do you have any comments you'd like to add? 8. Compliance ProcessSince Redhawk’s last site visit, have you needed to implement remediation procedures as a result of internal or regulator findings?* Yes No Who has overall responsibility for this process?*Were there any material compliance matters noted in the report?* Yes No What were they, and how were they handled?*Were any policies and/or procedures changed as a result of the matter?* Yes No What policies and/or procedures were changed?*Do you have any comments you'd like to add? 9. Proxy VotingDo you vote proxies on behalf of clients?*It is against Redhawk's policy to vote proxies on behalf of clients. All proxy material must be delivered to the client and cannot be routed to their advisor. Yes No Do you have any comments you'd like to add? 10. Sub-Advisor Due Diligence and MonitoringDo you use Sub-advisor(s)?* Yes No What is your process for monitoring and reconciling portfolio activities managed by the Sub-advisor?* Yes No Have you reviewed best execution of the sub-advisor(s)?* Yes No Is the review documented?* Yes No Please provide documentation details.*Did you conduct initial documented due diligence on the Sub-advisor?* Yes No Were compliance personnel involved?* Yes No Is it documented?* Yes No Do you conduct ongoing documented due diligence on the Sub-advisor?* Yes No Please provide your latest findings.*Were compliance personnel involved?* Yes No Who has responsibility for the Sub-advisor due diligence and reporting?*Are there periodic site visits?* Yes No How often?*Who conducts these visits?*Is it documented?* Yes No Please provide documentation.*What is the frequency of communication with the Sub-advisor?*Calls/emails/committee meetings etc.How do you ensure that the Sub-advisor(s) will appropriately interface with your other service providers?*e.g. Custodian, Administrator, Securities Lending AgentAre you satisfied with the Sub-advisor(s) performance and responsiveness?* Yes No Why not?*Do you have any comments you'd like to add?10A. Financial Intermediary OversightDo you use an entity that provides omnibus services?* Yes No Did you review the selling/operating agreement?* Yes No Have you accounted for financial intermediary risk in its risk assessment?*Legal/regulatory risk, reputation risk, financial risk. Yes No Have you reviewed an SSAE 16 or similar report from the intermediary?* Yes No What is the frequency of your interaction with the intermediary?*Over the last 12 months, have you experienced any issues with the intermediary?* Yes No Do you have any comments you'd like to add? 11. Business Continuity/Disaster RecoveryWhat are the perceived biggest risks to your firm and what provisions are being made?*Do you have documentation of protocols in various business disruption and disaster scenarios (Disaster Recover and Business Continuity plans)?* Yes No Would you like Redhawk to send you a Disaster Recovery and Business Continuity plan template to customize for your firm?* Yes No If there are multiple owners, is there a buyout plan/agreement?* Yes No Is there key man insurance?* Yes No Is there E&O insurance (beyond Redhawk’s policy)?* Yes No Do you have any comments you'd like to add? 12. Electronic CommunicationDo you communicate with clients about advisory service-related items via text message?*MyRepChat is the only approved text messaging platform that can be used for communicating about account and advisory service-related items. Any text messaging communication outside of MyRepChat is against Redhawk's policy. Yes No What platform do you use to text clients?*Do you have any comments you'd like to add? 13. Other13A. Privacy and Data SecuritySince the last site visit, has there been a successful cyber-security attack on your systems?* Yes No What remedial steps were taken in response to such breaches including any notifications to governmental agencies or clients required by federal or state law?*Is your data stored with a third-party?* Yes No Where is your data stored?*Does the third-party have privacy and security safeguards in place?* Yes No Do you use a shredder or shredding service when disposing of paper documents containing personally identifiable information relating to your clients or associates* Yes No How do you protect off-site use of data?*Physical theft of laptop/computer and or external hard drives or other physical media storage, as well as data.Do you store data from the network on a personal computer?* Yes No Do you have dual use (personal/business) devices (phones, iPads, etc.)?* Yes No How do you ensure data security?*Prior to sharing any confidential information with a third party (i.e., CPA, Attorney, etc.), do you or your IARs receive authorization from the respective client?* Yes No Please explain.Do you have any comments you'd like to add?13B. Marketing/Advertising/Quarterly LetterDo you submit all advisory client-facing marketing materials to Redhawk for pre-approval before disseminating?* Yes No Do you maintain a marketing log, and maintain a record of all materials approved?* Yes No Do you use financial planning software or generate financial plans for use with clients? Yes No Please list the software or tool used.Please upload a sample copy of a recent plan generated for a client.Max. file size: 128 MB.Have you or any IAR given to, or received a gift from, a client, in excess of $100? Yes No Please describe or provide documentation of a gift log.Are you, or are any of your IAR’s, a member of an investment club? Yes No Are you, or are any of your IAR’s, a trustee, custodian, POA, executor, joint tenant, other named fiduciary to any accounts (including immediate family)? Yes No Are you, or are any of your IARs, acting as a beneficiary or annuitant on any non-immediate family accounts? Yes No Are fixed insurance, advisory, and securities files separated? Yes No Do all IAR’s meet with clients for whom they provide ongoing advisory services and conduct an annual client review? Yes No Do IARs verify the accuracy of the client’s current investment objectives, risk tolerance, financial needs and financial information? Yes No Do you have any comments you'd like to add?13C. Social MediaHave you reported all social media accounts (business or personal) that mention your advisory services to Redhawk?* Yes No Please list any previously undisclosed social media accounts.*Do you have any comments you'd like to add?13D. RecordsWhat is the retention period of your records?*How do you maintain records in a way that secures them from unauthorized alteration or use?*Do you have any comments you'd like to add?13E. Final QuestionAre there any other material issues that we should be aware of and not previously discussed?Signature*Date* MM slash DD slash YYYY