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- Are you registered with the SEC or a state securities regulator as an investment adviser? If so, have you provided me with all the disclosures required under those laws (including Part II of Form ADV)? North Pier is an SEC Registered Investment Advisor. All disclosures including Part II of Form ADV are provided when required.
- Do you or a related company have relationships with money managers that you recommend, consider for recommendation, or otherwise mention to the plan? If so, describe those relationships. North Pier does not maintain any relationships with investment managers beyond essential interaction for research and due diligence.
- Do you or a related company receive any payments from money managers you recommend, consider for recommendation, or otherwise mention to the plan for our consideration? If so, what is the extent of these payments in relation to you other income (revenue)? No.
- Do you have any policies or procedures to address conflicts of interest or to prevent these Payments or relationships from being a factor when you provide advice to your clients? Yes, North Pier has policies and procedures designed to eliminate all avoidable conflicts of interest, which are available upon request. As stated in question 3, North Pier does not maintain relationships or accept payments from money managers which could lead to potential conflicts of interest.
- If you allow plans to pay your consulting fees using the plan's brokerage commissions, do you monitor the amount of commissions paid and alert plans when consulting fees have been paid in full? If not, how can a plan make sure it does not over-pay its consulting fees? Not applicable.
- If you allow plans to pay your consulting fees using the plan's brokerage commissions, what steps do you take to ensure that the plan receives best execution for its securities trades? Not applicable.
- Do you have any arrangements with broker-dealers under which you or a related company will benefit if money managers place trades for their clients with such broker-dealers? No.
- If you are hired, will you acknowledge in writing that you have a fiduciary obligation as an investment adviser to the plan while providing the consulting services we are seeking? Yes.
- Do you consider yourself a fiduciary under ERISA with respect to the recommendations you provide the plan? Yes.
- What percentage of your plan clients utilize money managers, investment funds, brokerage services or other service providers from whom you receive fees? 0%
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