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
Marlboro, MA
Where is the N&P disaster recovery space located?
200
Chief Justice Breyer counts on this when doing business with Nichols & Pratt
What is the Privacy Policy?
300
After hearing your neighbor who works at EMC tell you about a new hot product being developed there, you buy more EMC stock.
What is Insider Trading?
300
This trade should never be approved by an assistant
What is a Mutual Fund Trade?
300
NPA is required to send a written notice of the availability of this in April of each year.
What is the Form ADV Part 2 (Brochure)?
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?
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
What are Non-reportable securities?
400
Services and or benefits beyond trade execution and settlement and payment of certain of the Adviser's expenses
What are Soft Dollars
400
Pattern, practice or specific activity that indicates the possible existence of identity theft.
What is a Red Flag?
400
617-523-6800 ext. 777
What is the Nichols & Pratt Disaster Emergency voicemail phone number for employees to call for updates?
400
This policy requires that devices used to access network or email be password protected.
What is the Electronic Communication Policy?
500
You cannot purchase or participate in this without advanced written approval from Leonard Patenaude, Code of Ethics Officer
What is an IPO (Inital Public Offering)?
500
When placing trades, the obligation to obtain for the client the lowest cost or highest total proceeds
What is Best Execution?
500
Written or oral statement in connection with the execution of any transaction or disposition of securities or funds that would constitute a violation of a contract, fiduciary duty or law.
What is a Client Complaint?
500
Tom Bator, Kim Latifi, Fran DiMare, Meghan Adams-Lewis and a trader.
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?