The document that holds our office to a standard of utmost ethical conduct.
What is the “Code of Ethics”
100
Action required to be taken before an employee trades in a reportable security
What is "Preclearance"
100
The report a Covered Person is required to complete every 90 days.
What is the "Quarterly COE Affirmation"
100
Information that would be considered relevant to an investor who is considering investing in a particular stock, that is not publicly known.
What is “Material Non-Public Information”
100
The “de minimis” amount for gifts.
What is “a total of $250 in any 12-month period”
200
Our electronic compliance surveillance system.
What is "Compliance11"
200
Transactions in a single issuer having an aggregate market value of less than $2500 in a rolling 30-day period.
What are "De Minimus Transactions"
200
The questionnaire a Covered Person is required to fill out once every 365 days.
What is the "Annual Affirmation"
200
When a person directly or indirectly through any contract, arrangement, understanding, relationship or otherwise has a direct or indirect pecuniary interest in securities.
What is "Beneficial Ownership"
200
Two special types of investments that always require preclearance.
What are “Initial Public Offerings and Private Placements”
300
Someone who has an affirmative duty of care, loyalty, honesty and good faith to act in the best interest of their clients.
What is a "Fiduciary"
300
A buy-buy or sell-sell transaction where the client purchases and the covered person purchases the same security or the client sells and the covered person sells the same security.
What is a "Matching Transaction"
300
A brokerage account over which the owner does not have discretionary trading authority.
What is a "Managed Account"
300
Open-end mutual funds, U.S. Treasury Securities, CDs, Commercial Paper and Repurchase Agreements, Shares of Money Market Funds, etc.
What is a “Non-Reportable Security”
300
Two people that make up the “Compliance Committee.”
What are the “Fund CCO and any one non-interested director”
400
An employee that is privileged to material non-public information and who is required to comply with the COE.
What is a "Covered Person"
400
A buy-sell or sell-buy transaction where the client purchases and the covered person sells the same security, or the client sells and the covered person purchases the same security.
What is a "Non-Matching Transaction"
400
The length of time that COE records are required to be kept.
What is “at least six years after the end of the fiscal year, the first two years in an easily accessible place”
400
A roster containing issuers of securities that the Advisers are actively analyzing and considering as investment candidates for their clients.
What is the "Watch List"
400
The sanction imposed for the violation of failing to preclear a transaction that would have been approved.
What is a “Reminder memo”
500
All securities that are required to be precleared, not including open-end mutual funds, U.S. treasury securities, CDs, commercial paper and repurchase agreements, shares of money market funds, etc.
What is a "Covered Security"
500
The opportunity, directly or indirectly, to profit or share in any profit derived from a transaction.
What is "Pecuniary Interest"
500
How much time does a covered person have in order to provide compliance with a list of brokerage accounts and a holdings report?
What is "10 Calendar Days"
500
A roster containing any issuers of which the Advisers are in possession of material, non-public information.
What is the "Restricted List"
500
The sanction imposed for the violation of failing to preclear a transaction that would not have been approved (list two out of the possible three).
What is the “Immediate sale, disgorgement of profits, and/or suspension of personal trading”