Personal Trading
Gifts & Entertainment (Permissible OR Prohibited)
Cybersecurity & Privacy
Reporting
If You Know This, You're Good
100

Action required by an employee prior to trading an Exchange Traded Product (ETP) valued at $10,000 or more.

What is “Pre-clearance “

100
  • Sent $150 worth Graeter’s Ice Cream to a client.
  • What is a “permissible gift”
100
  • Social security number, date/place of birth, home address, email address, mother’s maiden name are all considered as.
  • What is Personally Identifiable Information (PII)
100
  • The period of time after quarter end that an employee has to submit their Quarterly Personal Securities Report.

What is "30 days"

100
  • Per the SEC, regardless of the type of client relationship, the ability to move money on behalf of a client deems you to have this and subjects us to a surprise audit
  • What is “custody”
200
  • Upon pre-clearance approval, number of business days to submit trade.
  • What is “Two”
200
  • Received $350 valued golf bag from a manager but it also has the manager’s logo on it.   
  • What is a “prohibited gift”
200

This is a type of online scam where criminals send an email that appears to be from a legitimate company and ask you to provide sensitive information.

  • What is “phishing email”
200

All FEG employees are required to submit this type of report via SCT before making any political contributions.

  • What is a "pre-clearance report"

200
  • Statement that omits material facts and circumstances necessary for an investor to make an informed decision.
  • What is “False or misleading statement”
300

When a person directly or indirectly through any contract, arrangement, understanding, relationship or otherwise has a direct or indirect monetary interest in securities

  • What is “Beneficial Ownership”
300
  • Took a group of 5 individuals for a golf outing and spent a total of $1500 for the whole event
  • What is “permissible entertainment”
300
  • This is an email or electronic communication scam targeted towards a specific individual, organization or business often intended to steal data for malicious purposes or install malware on a computer.
  • What is “spear phishing email”
300
  • An FEG employee’s outside employment at a local non-profit board or committee is required to be reported on this form.

What is an "Outside Business Activity form"

300
  • Backup server and business recovery site for FEG’s Cincinnati office.

What is "Indy Office"

400
  • Two “special” types of investments that always require pre-clearance.
  • What are “Initial Public Offerings (IPOs) & Private Placements” (including FEG’s proprietary funds)
400
  • Accepted a speaking engagement at a conference and got airline and hotel paid for.
  • What is an “prohibited gift”
400
  • Software designed to protect devices and networks from malware. They act as a wall of protection.
  • What is a “firewall”
400
  • An employee who upon observing a co-worker who is violating established FEG policies, reports the issue to the CCO

What is a "whistleblower"

400
  • Time period required to maintain data supporting performance advertising.
  • What is six years (or no less than five) after the end of the fiscal year which performance was last used.
500
  • According to the Blackout Period, the total number of calendar days an employee or employee related account is restricted from completing a personal securities transaction in the same security as a client transaction.
  • What is “Fourteen” or “Seven prior/Seven after trade date”
500
  • Sent a $200 gift to John Doe of the University of Lame Ducks Foundation for his birthday. Later for Christmas, sent a $150 bottle of bourbon.  
  • What is a “prohibited gift”
500
  • Overarching document/plan responsible for guiding the actions taken by an FEG employee and management in case of a data breach.
  • What is “Incident Response Plan”
500
  • If you believe that you have material nonpublic information, under FEG’s Code of Ethics, prior to taking any action, you are required to report it immediately to this individual.

What is "the CCO"

500
  • An investment advisory firm has maintained all electronic communications (emails) since the firm’s inception 20 years ago. If requested, all those emails are subject to discovery by the SEC during an exam (True/False)
  • What is "true"
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