Conflict of Interest Policy

When potential conflicts of interest arise, Federal Financial Analytics makes the initial judgment as to whether a conflict may occur. Should one appear likely and material, the assignment is declined, with an indication to the prospective client only that such a conflict has been determined. No information on the nature of the conflict or with whom it may occur is provided. When managing partners determine that a conflict may be manageable, the current client is advised of the prospective assignment, without release of any confidential information on the prospective client. Should a full conflict determination be possible only with confidential information (such as the name of the prospective client), FFA receives permission to provide this information from the prospective client to the current one prior to doing so. If the current client believes a conflict exists, then the prospective assignment is declined or revisions to it are made. The prospective client is advised of all information necessary for it also to determine if a conflict may exist, based on the willingness of the current client to provide any proprietary information required for it to do so.