Stephen Roman, CFA

• Responsible for the development, oversight and enforcement of the company’s Investment Advisers Act compliance program, including the Code of Ethics, Code of Business Conduct, Insider Trading Policies, Cyber Security Policy and Business Continuity Plan.

• Implemented the compliance program and testing procedures relating to the company’s Investment Company Act registered business development company, as well as serving as corporate secretary for the Board of Directors.

• Provide advice on general corporate law matters including corporate governance matters, securities law, employment issues, confidentiality/non-circumvention agreements, service agreements and insurance related matters.

• Draft and/or review various public securities law filings, including Securities Act registration statements in connection with the public offering of fund interests and periodic Exchange Act reports, including Form 10-K, Form 10-Q and Form 8-K.

• Review marketing materials for compliance with regulatory guidelines and line of business standards.

• Managed extensive firm-wide due diligence efforts with broker-dealers and third party due diligence providers

• Conducted research and drafted memoranda focusing on tax law and commercial litigation.
• Assisted in preparation of documents for Internal Revenue Service and State Department of
Revenue tax audits and appeals, IRS ruling requests, and federal and state tax litigation.