Show:
Pre-Approval Questions (T/F)
Using Financial Tracking
Is this a violation?
Covered Accounts
Political Contributions
100

I have notified Compliance of my Fidelity account and it has been linked to SchwabCT by a member of the Compliance Department. Therefore, I do not have to get pre-approval for any covered transactions?

What is False? 

You must request pre-approval for all ETPs above the de minimus amount, including those processed through one of the designated brokers.

100
True or False: I submitted a trade request to sell my shares of APPLE at 10:00 AM and I was denied. It is now 3:00 PM, and I submitted for pre-approval a second time to sell my shares of APPLE and was approved. Even though I was denied approval this morning, I am still allowed to execute the trade since I was approved at 3:00 PM.
True. If you receive approval to execute a transaction, you ARE allowed to transact even if you were denied earlier in the day.
100

Yes or No: I requested pre-approval to purchase the same ETF a few days in a row and was auto-approved each time. I traded the same ETF today without requesting pre-approval, but I am confident I would be approved. Is this a violation?

Yes. You must request pre-approval for each covered transaction each time you would like to transact.

100
True or False: The following types of accounts are considered Covered Accounts under the Code: Mutual Fund Only Accounts, 529 Plans, and bank certificates of deposit.
False. Covered accounts are accounts in which an employee has direct ownership, beneficial ownership authority, and indirect ownership/influence, interests bequeathed through trusts, estates, partnerships, and corporations.
100

True or False: Manning & Napier defines a Covered Associate as people in a position of influence in regards to the Firm, or whose departments are involved in soliciting government entities.

True. Please refer to the Pay to Play policy for a detailed explanation of a covered and non-covered associate. You can also call Liz Craig (ext 8387) for further questions.

200

True or False: The trading window to sell MN stock will open the second trading day after the release of the quarterly earnings and will remain open for 30 calendar days.

True. You must request pre-approval through Financial Tracking to transact in MN stock.

200
True or False: I submitted a trade request and the request says in Financial Tracking that it is PENDING. I will be notified via email whether my request is APPROVED or DENIED.
True. An email will be sent to your work email indicating if you are APPROVED or DENIED.
200
Yes or No: I requested pre-approval to purchase shares of Time Warner Cable yesterday at 3:30 PM and was approved at 3:45 PM. Since the New York Stock Exchange closed before I could execute the transaction, I waited to place the order at 9:30 AM the following morning. Is this a violation?
Yes. Your approval is only valid from the time the approval is received until the close of the market on which you are executing the transaction. Approvals for transactions on foreign exchanges that may be in a different time zone are only valid until the next close of that market.
200
Yes or No: I currently live at home with my parents who both trade covered securities in their brokerage accounts. Should this be reported as a covered account?
Yes. Any immediate family member whom you live in the same household with is subject to the personal securities policies and procedures as defined in the Code.
200
True or False: Covered Associates must obtain pre-approval for political contributions through Financial Tracking?
True. Covered Associates are required to obtain pre-approval through the Campaign Checks module on Financial Tracking.
300
Yes or No: I live at home with my father who has his own brokerage account with TD Ameritrade. Do I need to notify Compliance of this account?
Yes. Accounts held by family members who live in the same household as you are subject to the Code of Ethics policies, and therefore must be disclosed to the Compliance Department and all covered transactions in the account must be pre-approved prior to execution.
300
I would like to request pre-approval to participate in an Outside Business Activity. Where on Financial Tracking must I request pre-approval? a. New Activity Request b. New trade request c. Campaign Checks Module
A. New Activity Request. Please contact Sarah Spiggle (ext 8686) or Samantha Larew (ext 8516) for questions on OBAs.
300
Yes or No: My father, who lives in my same household, bought shares of JP Morgan today. I was not aware of this and did not request pre-approval. Is this a violation?
Yes. If you live in the same household with an immediate family member who has a covered account, all covered transactions within the account are subject to pre-approval.
300
Yes or No: I have a stock option plan that was set up by my previous employer. Is this a covered account?
Yes. Any account in which you can hold, buy or sell stock is deemed a covered account.
300
True or False: A Covered Associate may contribute up to $350 per election to an elected official for whom the Covered Associate is entitled to vote.
True. A Covered Associate may: contribute up to $350 per election to an elected official or candidate for whom the Covered Associate is entitled to vote, and up to $150 per election to an elected official or candidate for whom the individual is not entitled to vote.
400
True or False. I would like to request pre-approval to participate in a private placement. I must contact Compliance to request pre-approval.
True. You must contact Cathryn Kittelberger (ext 8664) or a member of the Compliance Department for pre-approval for all private placements. Pre-approval is not to be obtained through Financial Tracking for private placements.
400
Yes or No: I would like to submit a trade request to purchase shares of a security in my new Rollover IRA at TD Ameritrade. However, I do not see the account listed on Financial Tracking. Do I need to contact Compliance about this new account even though it is held with one of the Firm’s designated brokers?
Yes. You must contact Compliance within 10 business days of opening all covered accounts.
400
Yes or No: I purchased shares of an open-end mutual fund but did not request pre-approval. Is this a violation?
No. Open-end mutual funds are non-covered investment vehicles and therefore do not require pre-approval.
400
True or False: Employees must disclose new covered accounts to Compliance within 30 calendar days.
False. You must disclose all covered accounts within 10 business days of opening a new covered account.
400
True or False: The Advisor may be prohibited from receiving advisor fees if a Covered Associate makes a greater than deminimis contribution to certain government officials or entities?
True. The Advisor may be prohibited from receiving advisory fees for providing investment advisory services to government officials or entities in question for a two year period.
500
Yes or No: I requested pre-approval and was approved to purchase shares of GOOGLE in my IRA account. Does this mean I am also approved to purchase shares of GOOGLE in my wife’s IRA account?
No. You must request pre-approval for each account in which you want to execute a covered transaction.
500
True or False. I received an email indicating that I must log onto Financial Tracking to complete the quarterly certification. However, since I do not have any covered accounts, nor do I engage in personal security trading, I am not required to complete it.
False. All employees are held to the Code of Ethics and therefore must complete the quarterly certifications.
500
Yes or No: I have stock held in certificate form that was granted to me by my grandfather when I was a kid, but did not disclose this to Compliance. Is this a violation?
Yes. Stock certificates are covered investment vehicles and must be disclosed to Compliance.
500
Yes or No: I have assumed the role as executor of the estate for my deceased relative who holds three accounts at Merrill Lynch. Must I disclose this as a covered account?
Yes. Once you assume the role as executor of an estate, you are required to disclose this to Compliance.
500
Yes or No: A close family friend is running for local office and I would like to attend a campaign dinner in support of the election. As a Covered Associate under the policy, am I required to obtain pre-approval to purchase a ticket to this event?
Yes. Ticket proceeds for events such as this are often given to the candidate in the form of a political contribution. Before purchasing a ticket to any campaign event, confirm whether the ticket proceeds will be recorded as a political contribution. Covered Associates must obtain pre-approval before making any contribution. Non-Covered Associates are requested to report these contributions on a quarterly basis.