Institutional Separate Accounts - Through our trade order management system, we track sector and securities weightings and monitor a portfolio's structure and individual holdings. Federated's Compliance Department monitors post-trade reports from various investment and trading systems to identify exceptions and facilitate any necessary corrective action in order to adhere to the stated SRI/ESG investment limitations articulated in the institutional separate account accounts guidelines. In addition, Federated's Audit Department conducts periodic audits to ensure investment management controls, including those related to guidance adherence are operating properly.
Separately Managed Accounts - On a quarterly basis, Portfolio Management will provide to Managed Account Operations a current list of securities that fall under the class restriction list. Managed Account Operations updates the Portfolio Accounting System as necessary. If a security is added to a class restriction list at the end of any given quarter and it is held in any client account that has a particular class restriction, the financial advisor on the account will be contacted to determine whether the security should be immediately sold from the client account or held and no further securities purchased.