Code of Ethics
Pot Luck
Privacy
AdvaMed Code
100

This "Code" sets out the expectations of every ResMed employee on how they should act in all of our business activities.  

What is Code of Conduct?

100

Merriman must maintain books and records for a period of not less than this many years from the end of the applicable fiscal year

What is 5 years?

100
Personally identifiable information that is provided by a consumer to a financial institution that is not generally common knowledge
What is nonpublic personal information?
100

The disclosure document in which Merriman sets forth its best execution policies and procedures

What is ADV part 2 and Schedule F?

200

Questions in interpreting the Code of Ethics should be directed to this person or persons

Who is the Chief Compliance Officer or the Compliance Department?

200

Length of time Merriman has to produce records requested by the SEC that are stored off-site

What is 24 hours?

200
People using client nonpublic personal information to gain access to clients’ custodial account(s) are engaged in this
What is identity theft?
200
Combining purchases or sales for the same securities for several clients at the same time
What is bunching?
300

Knowledge about ResMed or its products that has not been publicly disclosed and could affect the market price of the company’s securities

What is non-public confidential information?

300
Electronic correspondence to/from outside legal counsel is this type of communication
What is privileged communication?
300
Erasing information stored on electronic media and shredding paper documents are examples of this
What are proper disposal procedures?
300
Exclusive of client directed brokerage accounts, Merriman reviews and reconciles transactions for client accounts on this basis
What is daily (next day)?
400
The vast majority of state securities authorities require state registered investment advisers to comply with this organization’s record keeping requirements
What is the SEC?
400
The document Merriman is required to send annually detailing how client information is secured
What is the Privacy Notice?
400
An arrangement in which a firm receives investment research products and/or services in exchange for effecting securities transactions through the broker-dealer
What is a soft dollar arrangement?
500
An Access Person having indirect interest (the ability to profit) in reportable securities
What is beneficial ownership?
500
This type of record may need to be kept longer than 5 years
What are performance advertising records?
500
This Regulation requires Merriman to establish appropriate standards concerning the security of client nonpublic personal information
What is Regulation S-P?
500
Best execution requires Merriman to have its customer’s orders executed at prices that are as favorable as possible under these conditions
What are prevailing market conditions?
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