Form ADV Content Management Procedures

1 Purpose

This procedure establishes controls for managing Form ADV content to ensure proper segregation between draft regulatory updates and published public materials, preventing inadvertent disclosure of non-public information.

2 Scope

This procedure applies to all Form ADV-related content, including: - Form ADV Part 2A narrative sections - Investment strategy descriptions - Fee disclosures - Risk disclosures - Regulatory information - Website content that references Form ADV

3 Repository Structure

3.1 Private Repository (~/docs)

Location: /Users/srvo/docs/compliance/form-adv-includes/

Content Types: - form-adv-part-2a-draft.qmd - Complete draft Form ADV for regulatory filing - investment-process.qmd - Draft investment process narrative - investment-strategies.qmd - Draft strategy descriptions - risk-disclosures.qmd - Draft risk disclosure language - services-and-fees.qmd - Draft fee structure and service descriptions - adv-section-map.yml - Mapping of content to Form ADV sections - runbook-alignment.yml - Integration with operational procedures

Published Subfolder: published/ - Contains currently filed Form ADV language - Used for public website references - Updated only after successful regulatory filing

3.2 Public Repository (~/ethicic-site)

Restriction: May only reference published Form ADV content Location: Public website includes system Content: Marketing materials consistent with filed regulatory documents

4 Content Management Workflow

4.1 1. Form ADV Updates

Draft Phase: 1. Updates created in private repository draft files 2. Integration with current public website copy for consistency 3. Legal review and compliance verification 4. Internal review and approval

Filing Phase: 1. Complete Form ADV assembled from draft includes 2. Filed with Utah Division of Securities 3. Regulatory approval received

Publication Phase: 1. Approved language moved to published/ subfolder 2. Public website updated to reference new published content 3. Draft files prepared for next update cycle

4.2 2. Public Website Maintenance

Permitted References: - Content from published/ subfolder only - General marketing materials not requiring regulatory filing - Educational content consistent with filed documents

Prohibited Content: - Draft Form ADV language - Internal compliance procedures - Regulatory correspondence - Proposed but not filed updates

4.3 3. Consistency Verification

Regular Checks: - Monthly review of public website for regulatory consistency - Quarterly verification of fee disclosures - Annual comprehensive review with Form ADV filing

Documentation: - Track all content movements between draft and published - Maintain version control for regulatory content - Document approval process for public content updates

5 File Organization

5.1 Current Structure

~/docs/compliance/form-adv-includes/
├── published/                    # Filed regulatory content
│   ├── firm-description.qmd
│   ├── regulatory-information.qmd
│   └── services-and-fees.qmd
├── form-adv-part-2a-draft.qmd    # Complete draft for filing
├── investment-process.qmd         # Draft process description
├── investment-strategies.qmd      # Draft strategy narratives
├── risk-disclosures.qmd          # Draft risk language
├── principal-personnel.qmd        # Personnel information
├── services-and-fees.qmd         # Draft service descriptions
├── adv-section-map.yml           # Content mapping
└── runbook-alignment.yml         # Operational integration

5.2 Access Controls

Private repository: Chief Compliance Officer only
Published content: May be referenced by public website
Draft content: Internal use only until filed

6 Compliance Requirements

6.1 Regulatory Consistency

All public investment strategy descriptions must align with filed Form ADV Part 2A Item 8
Fee disclosures must match currently effective fee schedules in Form ADV Part 2A Item 5
Risk disclosures must be consistent with filed regulatory language
Personnel information must match Form ADV Part 2B disclosures

6.2 Documentation Standards

Maintain record of all Form ADV content changes
Document regulatory filing dates and approval status
Track version control for all regulatory content
Preserve audit trail for content movement between repositories

6.3 Review Schedule

Monthly: Public website compliance review
Quarterly: Fee disclosure verification
Annually: Complete Form ADV update and filing
As Needed: Material change amendments

7 Responsibilities

7.1 Chief Compliance Officer

Approve all Form ADV content updates
Ensure compliance with regulatory requirements
Oversee content movement between draft and published
Conduct regular compliance reviews
Maintain documentation and audit trails

7.2 Content Management

Execute approved content updates
Maintain repository organization
Implement access controls
Support compliance reviews

9 Implementation Notes

Effective Date: September 27, 2025 Next Review: September 27, 2026 Change Control: All updates require CCO approval and documentation in compliance change log

This procedure ensures regulatory compliance while enabling efficient content management and website maintenance.