Safekeeping of Your Assets with Kayne Anderson
Below are the primary structural and operational characteristics
which protect your Kayne Anderson assets from non-investment
risk.
SEC Registration and Review
Kayne Anderson has been registered with the SEC since our
inception in 1984, and is regularly audited by that agency.
Information on results and responses to past audits is available
upon request.
Comprehensive Financial Audits
Our investment partnerships are audited by an independent
auditor, Rothstein Kass & Company, a leading accounting firm
with expertise in the field of alternative investment management.
Audit work is performed continuously throughout the year by a team
of auditors, and such work includes review of valuation of private
securities.
Independent Board Oversight
Our publicly held closed-end funds are subject to the oversight
of Boards of Directors having a majority of independent directors.
Among other matters, the Boards review portfolio activity and
compliance, financial reporting, valuations and regulatory
compliance on a quarterly basis. The funds also utilize third-party
administrative and fund accounting services.
Investor Transparency
We provide investors with transparency in our investment
processes, regularly undergoing due diligence meetings with leading
institutional investors. We publicly report public equity holdings
on a quarterly basis and such information is available through the
SEC website.
Independent Custody of Assets
Client assets are held in safekeeping at one of two prime
brokers, J.P. Morgan or UBS, and in certain circumstances
collateral held against contracts is held at one of a number of
major banking institutions including Morgan Stanley, Goldman Sachs,
and Royal Bank of Canada. In no circumstance is client money held
by Kayne Anderson directly.
Funds Transfers
Wire transfers and other funds transfer instructions require two
signatures of senior Kayne Anderson personnel. Funds transfer
instructions are created and records maintained by staff separate
from the accounting department, with oversight by the Chief
Financial Officer.
Trade Execution
Trades are conducted with a broad selection of external
broker/dealers. KA Associates, a broker/dealer affiliated with
Kayne Anderson, does not execute trades for or otherwise transact
with our managed funds.
Internal Compliance
We maintain internal oversight of trading and portfolio
management through a compliance team separate and distinct from the
portfolio managers, consisting of legal counsel, a chief compliance
officer, trading compliance officer, and a risk manager. Internal
financial reporting, overseen by the CFO and two controllers, is
reviewed by senior executives of Kayne Anderson on a regular
basis.