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PMAM Strategy PMAM generally manages client investment accounts or portfolios with a determined investment strategy, and the investment decisions are consistent with client written investment objectives, guidelines, limitations, and restrictions. Depending on the terms of the arrangement with clients, PMAM may perform day-to-day investment management services directly or retain independent investment advisers (referred to as Sub-Advisers), to manage a portion or all of a client investment portfolio. PMAM also offers a fee-based advisory wrap program for its insurance company clients. It is a customized discretionary investment advisory program to bundle fees for services associated with: investment management; custodian fees; proxy fees; and brokerage or other transaction costs. PMAM Regulators and Regulation PMAM is primarily regulated by the U.S. Securities and Exchange Commission (SEC). It is also subject to review and examination by the National Futures Association (NFA), which is a Self-Regulatory Organization (SRO) tasked by the Commodity Futures Trading Commission (CFTC) to oversee the U.S. futures and derivatives markets. SROs, like NFA and FINRA, are entities organized to regulate practices and business conduct of its member firms to protect investors. PMAM is also subject to federal and state regulatory reporting requirements. As a Registered Investment Adviser (RIA), PMAM is governed by the Investment Advisers Act of 1940 (Advisers Act). This Act focuses on an investment adviser's fiduciary duty to protect investors. It requires RIAs to adopt policies and procedures to guide their advisory practices. In addition to the Advisers Act, PMAM may need to comply with other regulations. As regulation is adopted, PMAM must evaluate applicability, design appropriate controls and practices to comply, and adopt policies and procedures that not only meet regulatory standards, but also align with management objectives, which often set a higher bar. Breaking News On October 23, 2023, the SEC published its 2024 Regulatory Priorities. These published priorities offer Registered Investment Advisors (RIAs), such as PMAM, valuable insights into the key areas of concern for SEC examiners during their routine or targeted examinations, often referred to as sweep exams: Compliance Programs Investment Advice Disclosure of Conflicts of Interest Fiduciary Duty Risks Related to Fees and Expenses Custody Investment Company Investor Disclosures and SEC Reporting Information Security and Operational Resiliency Crypto Assets Emerging Financial Technology New Regulation and Indirect Impact New regulations may indirectly require RIAs (like PMAM) to make changes to business practices, computer systems, and technology solutions. Here is an example of a recent impact. On May 28, 2024, the Shortening the Securities Transaction Settlement Cycle1, Rule 15c6-1 under the Securities Exchange Act of 1934 went into effect and indirectly impacted PMAM. This changed the standard settlement cycle for most brokerage transactions in U.S. securities from two business days after the trade date (commonly called "T+2") to ONE business day after the trade date ("T+1"). PMAM worked with its strategic partners and service providers to deploy new software integrations in advance of T+1 to assure compliance with the new regulation. PMAM actively monitors regulatory developments to provide assurance they are ready to comply—allowing uninterrupted investment adviser activity for clients.