CODE OF ETHICS
TRADING
CLIENT COMMUNICATION
DISASTER RECOVERY
MISCELLANEOUS
100
Someone who is privy to nonpublic information regarding client purchase or sales
What is an Access Person?
100
You have purchased the wrong security or the wrong amount of securities.
What is a trade error?
100
This is sent directly from the custodian to the client at a prescribed frequency.
What is a Quarterly Statement (APT Statement)?
100
In the event of a disaster, staff is asked to monitor this daily.
What is email (client requests)?
100
Your spouse, domestic partner, children, siblings, grandparents, parents, or in-laws living with you
What are Members of Family or Household?
200
Something given by a broker or dealer with a value greater than $300
What is the N&P Gift Policy?
200
If this information is missing from a trade ticket, the trader will not execute a trade.
What is investment discretion?
200
This document must be delivered to all perspective advisory clients.
What is the Form ADV Brochure & Privacy Policy?
200
All Partner, employees and critical vendors will be informed of a disaster using this document.
What is the call tree?
200
Our clients count on this when doing business with Nichols & Pratt
What is the Privacy Policy?
300
After hearing your neighbor who works at Fiserv tell you about a new hot product being developed there, you buy more Fiserv stock.
What is Insider Trading?
300
This trade should never be approved by an assistant
What is a Mutual Fund Trade?
300
Misrepresenting or failing to disclose material facts concerning an investment such as the risks of investing in a particular security would be an example of this
What is client complaint?
300
This book contains the Disaster Recovery Business Continuity Plan, the N&P employee address and alternative phone number list and the N&P Call Tree.
What is the Disaster Recovery Packet/Orange Binder?
300
This policy requires that communication that contains investment advice or recommendations or requests movement of funds or securities must be kept on file.
What is the Email Retention Policy?
400
US Gov't Obligations, CD's, Mutual Funds, Money Market Funds are considered what kind of securities in the Code of Ethics
What are Non-reportable securities?
400
These are filed by date and kept by the Firm in the Trader’s office.
What are broker confirms
400
Specific activity that indicates the possible existence of identity theft, such as an email money request or address change that doesn't make sense;
What is a Red Flag?
400
Certain original documents (wills, trusts and other special items) are stored offsite at this location
What is ACCESS/RETRIEVEX
400
This document must be completed when giving an ADV Brochure to a client (copies should also go in the red file and to the Compliance Officer's Assistant)?
What is Delivery of ADV-Part II to New Client form?
500
You cannot purchase or participate in an Initial Public Offering (IPO) without advanced written approval from NPA's Code of Ethics Officer
Who is Leonard Patenaude?
500
When placing trades, the obligation to obtain for the client the lowest cost or highest total proceeds
What is Best Execution?
500
Client complaints should be immediately brought to the attention of this person
Who is the Chief Compliance Officer (Kimberly H. Latifi)?
500
In the event of a disaster, this team will report to a temporary office space.
What is the Disaster Recovery Team?
500
This document providing the name and address of the qualified custodian must be sent in writing to a client when an account is opened.
What is the Notification to Client?