Black Cypress has established a comprehensive compliance program to demonstrate its commitment to transparency and ethical business practices. The firm’s Chief Compliance Officer oversees the program, which covers two main areas: Global Investment Performance Standards (GIPS®) and regulatory compliance in the states where the firm is registered as an investment adviser.

First, Black Cypress seeks to be transparent and consistent in the way it calculates and presents its performance. To that end, Black Cypress claims firm-wide compliance with GIPS, and this claim has been independently verified by ACA Compliance Group for the periods 10/21/2009 through 06/30/2017. Additionally, the firm’s Long-Only Equity Composite has been examined for the periods 03/31/2011 through 06/30/2017. The verification and performance examination reports are available upon request.

Second, Black Cypress ensures regulatory compliance through the implementation of written policies and procedures in its Compliance Manual. All of the firm’s team members are required to acknowledge and abide by these policies and procedures. The Compliance Manual includes a Code of Ethics, Business Continuity Plan, and Cyber Incident Response Plan.

Black Cypress prides itself on its ability to offer a compliance program that is comparable in sophistication and protection to that of a larger firm while still maintaining the agility and close client relationships of a smaller firm.

For more information on Black Cypress’s compliance program, please contact:

Jordan M. Roberts, Esq.

General Counsel and Chief Compliance Officer