JOINT
CODE OF ETHICS
OF
1838 INVESTMENT ADVISORS FUNDS
1838 BOND-DEBENTURE TRADING FUND
1838 INVESTMENT ADVISORS, LLC
MBIA CAPITAL MANAGEMENT CORPORATION
PREAMBLE
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This Code of Ethics has been adopted by
o the Board of Trustees of 1838 Investment Advisors Funds (the "Trust")
on behalf of each series of the Trust listed on Appendix A hereto;
o the Board of Directors of 1838 Bond-Debenture Trading Fund (the
"Fund");
o 1838 Investment Advisors, LLC ("1838 Advisors"), insofar as 1838
Advisors serves as investment adviser to the Trust and the Fund; and
o MBIA Capital Management Corporation ("MBIA"), insofar as MBIA serves as
principal underwriter for the Trust.
The Code has been adopted in accordance with the requirements
of Rule 17j-1 (the "Rule") under the Investment Company Act of 1940 (the "Act").
The Rule requires the Trust, the Fund, 1838 Advisors, and MBIA to adopt a
written code of ethics containing provisions reasonably necessary to prevent
persons from engaging in acts in violation of the Code and the Rule, and to use
reasonable diligence to prevent violations of the Code. Violations of
sub-paragraph (b) of the Rule may constitute grounds for the imposition of
significant administrative and civil injunctive, as well as criminal, sanctions
by the U.S. Securities and Exchange Commission or the federal courts. In
addition, the Trust or Fund may impose internal sanctions for violations of this
Code. All persons that are or that are about to become covered by this Code are
expected to be familiar with the proscriptions of this Rule. To that end, a
summary of Rule 17j-1(b) is included as Appendix B to this Code.
Set forth below is the Code of Ethics adopted by the Trust,
the Fund, 1838 Advisors, and MBIA in compliance with the Rule. This Code of
Ethics is based upon the principle that the trustees and officers of the Trust,
the directors and officers of the Fund, and certain affiliated persons of the
Trust, the Fund, 1838 Advisors and MBIA owe a fiduciary duty to, among others,
the shareholders of the Trust and/or the Fund to conduct their affairs,
including their personal securities transactions, in such manner to avoid (i)
serving their own personal interests ahead of shareholders; (ii) taking
inappropriate advantage of their position with the Trust or the Fund; and (iii)
any actual or potential conflicts of interest or any abuse of their position of
trust and responsibility.
1. DEFINITIONS
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The definitions of the terms used throughout this Code are
set forth in Appendix C.
2. PROHIBITED TRANSACTIONS
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(a) No Access Person shall engage in any act, practice or
course of conduct, which would violate the provisions of Rule 17j-1 set forth
in Appendix B.
(b) No Access Person shall:
(i) purchase or sell, directly or indirectly, any
security in which he or she has or by reason of such transaction acquires, any
direct or indirect beneficial ownership and which to his or her actual knowledge
at the time of such purchase or sale:
(A) is being considered for purchase or sale by
Trust or Fund, as the case may be, or
(B) is being purchased or sold by the Trust or
Fund;
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(ii) disclose to other persons the securities
activities engaged in or contemplated for the various portfolios of the Trust or
Fund;
(iii) seek or accept anything of value, either
directly or indirectly, from broker-dealers or other persons providing services
to the Trust or Fund because of such person's association with the Trust or
Fund. For the purposes of this provision, the following gifts from
broker-dealers or other persons providing services to the Trust or Fund will not
be considered to be in violation of this section:
(A) an occasional meal;
(B) an occasional ticket to a sporting
event, the theater or comparable entertainment, for which the Access Person
will reimburse the host;
(C) a holiday gift of fruit or other
foods; provided, however, that such gift is made available to all members of the
recipient's department.
(c) No Investment Personnel and no Access Person of
1838 Advisors shall:
(i) acquire directly or indirectly any beneficial
ownership in any securities in an IPO or in a Limited Offering without prior
approval of the Compliance Officer or other person designated by the Trust's
Board of Trustees or Fund's Board of Directors, as the case may be. Any person
authorized to purchase securities in an IPO or Limited Offering shall disclose
that investment when involved in the Trust's or Fund's subsequent consideration
of an investment in the issuer. In such circumstances, the Trust's or Fund's
decision to purchase securities of the issuer shall be subject to independent
review by the Trust's or Fund's officers, as the case may be, with no personal
interest in the issuer;
(ii) unless an exception is granted, profit in the
purchase and sale, or sale and purchase, of the same (or equivalent) securities
within sixty (60) calendar days. Any profits realized on such short-term trades
shall be subject to disgorgement, except that the provisions in this paragraph
2(c)(ii) shall not apply to the purchase and sale, or sale and purchase, of
MBIA, Inc. stock options.
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(iii) serve on the board of directors of any
publicly traded company without prior authorization of the Chairman and/or
President of the Trust or Fund, as the case may be. Any such authorization shall
be based upon a determination that the board service would be consistent with
the interests of the Trust or the Fund and the shareholders of the Trust or
Fund, as the case may be;
(iv) buy or sell a Covered Security within at
least seven (7) calendar days before and after any portfolio of the Trust or the
Fund trades in that security. Any profits realized on trades within the
proscribed period are required to be disgorged.
3. EXEMPTED TRANSACTIONS
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The prohibitions of Sections 2(b) and 2(c) of the Act shall
not apply to:
(a) purchases or sales effected in any account over which
the Access Person has no direct or indirect influence or control;
(b) purchases or sales which are non-volitional on the
part of either the Access Person or the Trust or Fund;
(c) purchases which are part of an automatic dividend
reinvestment plan;
(d) purchases effected upon the exercise of rights issued
by an issuer pro-rata to all holders of a class of its securities, to the extent
such rights were acquired from such issuer, and sales of such rights so
acquired; and
(e) purchases or sales of shares of any series of the
Trust.
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4. COMPLIANCE PROCEDURES
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(a) Pre-clearance
(i) With the exception of the Independent Trustees and
the Independent Directors, all Access Persons generally shall receive prior
approval from the Compliance Officer or other officer designated by the Board of
Trustees or Board of Directors, as the case may be, before purchasing or selling
securities.
(ii) The following transactions are exempt from prior
clearance requirements:
o Mutual Funds - purchases or redemptions of shares
of any open-end investment company, including 1838 Investment Advisors Funds and
any of its series.
o U.S. Government Obligations - purchases or sales of
direct obligations of the U.S. government.
o Municipal Bonds.
(b) Initial and Annual Holdings Reports
All Access Persons shall disclose to the Compliance Officer
within 10 days of becoming an Access Person, and thereafter on an annual basis
as of December 31, (i) the name, number of shares and principal amount of each
Covered Security in which the Access Person has any direct or indirect
beneficial ownership and (ii) the name of any broker, dealer or bank with whom
the Access Person maintains a securities account. The initial and annual reports
shall be made on the appropriate forms attached under Appendix D.
(c) Quarterly Reports
(i) Every Access Person shall report to the Compliance
Officer the information described below with respect to transactions in any
Covered Security in which such person has, or by reason of such transaction
acquires, any direct or indirect beneficial ownership in the security; provided,
however, that an Access Person shall not be required to make a report with
respect to transactions effected for any account over which such person has no
direct or indirect influence or control.
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(ii) Each Independent Trustee or Independent Director,
as the case may be, need only report a transaction in a security if such Trustee
or Director, at the time of that transaction knew, or, in the ordinary course of
fulfilling his official duties as a Trustee or Director, should have known that,
during the 15-day period immediately preceding or after the date of the
transaction by the Trustee or Director, such security was purchased or sold by
the Trust or the Fund, as the case may be, or was being considered for purchase
by the Trust or the Fund or by 1838 Advisors on behalf of the Trust or Fund.
(iii) Reports required to be made under this Paragraph
(c) shall be made not later than 10 days after the end of the calendar quarter.
Every Access Person shall be required to submit a report for all periods,
including those periods in which no securities transactions were effected. A
report shall be made on the Securities Transaction Report form attached hereto
under Appendix D or on any other form containing the following information:
With respect to any transaction during the quarter in a
Covered Security in which the Access Person had any direct or indirect
beneficial ownership:
(A) the date of the transaction, the name, the
interest rate and maturity date (if applicable), the number of shares, and the
principal amount of each Covered Security involved;
(B) the nature of the transaction (i.e.,
purchase, sale or any other type of acquisition or disposition);
(C) the price at which the transaction in the
Covered Security was effected;
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(D) the name of the broker, dealer or bank with
or through which the transaction was effected; and
(E) the date that the report is submitted by the
Access Person.
With respect to any securities account established at a broker, dealer or bank
during the quarter for the director or indirect benefit of the Access Person:
(A) the name of the broker, dealer or bank with
whom the Access Person established the
account;
(B) the date the account was established; and
(C) the date that the report is submitted by the
Access Person.
(iv) Any such report may contain a statement that the
report shall not be construed as an admission by the person making such report
that he or she has any direct or indirect beneficial ownership in the security
to which the report relates.
(d) Broker Confirms
With the exception of the Independent Trustees and
the Independent Directors, every Access Person shall direct his or her brokers
to supply to the Compliance Officer, on a timely basis, duplicate copies of the
confirmation of all personal securities transactions and copies of all periodic
statements for all securities accounts.
(e) Notification of Reporting Obligation
The Compliance Officer shall notify each Access
Person that he or she is subject to these reporting requirements, and shall
deliver a copy of this Code of Ethics to each such person upon request.
(f) Certification of Compliance with Code of Ethics
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(i) With the exception of the Independent
Trustees and Independent Directors, Access
Persons shall certify annually that:
(A) they have read and understand the Code
of Ethics and recognize that they are
subject thereto;
(B) they have complied with the requirements
of the Code of Ethics; and
(C) they have reported all personal
securities transactions required to be
reported pursuant to the requirements of the
Code of Ethics.
(g) Conflict of Interest
Every Access Person shall notify the Compliance Officer of any
personal conflict of interest relationship which may involve the Trust or the
Fund, such as the existence of any economic relationship between transactions
and securities held or to be acquired by any series of the Trust or the Fund.
Such notification shall occur in the pre-clearance process.
(h) Review of Reports
The Compliance Officer or a designate immediately shall review
all holdings reports submitted by each Access Person, including confirmations of
personal securities transactions, to ensure that no trading has taken place in
violation of the Rule or this Code of Ethics. Any violations of this Code shall
be reported to the Board of Trustees of the Trust, or the Board of Directors of
the Fund, as the case may be, in accordance with Section 5 of this Code. The
Compliance Officer shall maintain a list of the persons responsible for
reviewing the transactions and holdings reports.
5. REPORTING OF VIOLATIONS
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(a) The Compliance Officer shall promptly report to the
Board of Trustees or the Board of Directors, as the case may be:
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(i) all apparent violations of this Code of Ethics and
the reporting requirements thereunder; and
(ii) any reported transaction in a Covered Security
which was purchased or sold by the Trust or Fund within fifteen (15) days before
or after the date of the reported transactions.
(b) When the Compliance Officer finds that a transaction
otherwise reportable to the Board of Trustees or the Board of Directors under
Paragraph (a) of this Section could not reasonably be found to have resulted in
a fraud, deceit or manipulative practice in violation of Rule 17j-l(b), it may,
in its discretion, lodge a written memorandum of such finding and the reasons
therefor with the reports made pursuant to this Code of Ethics, in lieu of
reporting the transaction to the Board.
(c) The Board of Trustees or the Board of Directors, as the
case may be, or a Committee created by a Board for that purpose, shall consider
reports made to the Board hereunder and shall determine whether or not this Code
of Ethics has been violated and what sanctions, if any, should be imposed.
6. ANNUAL REPORTING
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(a) The Compliance Officer, 1838 Advisors and MBIA shall
furnish the Board of Trustees or the Board of Directors, as the case may be, an
annual report relating to this Code of Ethics. Such annual report shall:
(i) describe any issues arising under the Code of
Ethics or procedures during the past year;
(ii) identify any material violations of this Code or
procedures, including sanctions imposed in response to such violations, during
the past year;
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(iii) identify any recommended changes in the existing
restrictions or procedures based upon the Trust's or Fund's experience under its
Code of Ethics, evolving industry practices or developments in applicable laws
or regulations; and
(iv) certify that the Trust, Fund, 1838 Advisors and
MBIA have adopted procedures reasonably necessary to prevent Access Persons from
violating the Code of Ethics.
7. SANCTIONS
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Upon discovering a violation of this Code, the Board of
Trustees or Board of Directors, as the case may be, may impose such sanctions as
they deem appropriate, including, among other things, a letter of censure or
suspension or termination of the employment of the violator.
8. RETENTION OF RECORDS
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This Code of Ethics, a list of all persons required to make
reports hereunder from time to time, a copy of each report made by an access
person hereunder, a list of all persons responsible for reviewing the reports
required hereunder, a record of any decision, and the reasons supporting the
decision, to approve the acquisition by Investment Personnel of securities in an
IPO or Limited Offering, each memorandum made by the Compliance Officer
hereunder and a record of any violation hereof and any action taken as a result
of such violation, shall be maintained by the Trust and Fund as required under
Rule 17j-l.
9. ADOPTION AND APPROVAL
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The Board of Trustees of the Trust and Board of Directors of
the Fund, including a majority of the Independent Trustees or Independent
Directors, as the case may be, shall approve the Code of Ethics of the Trust or
the Fund, 1838 Advisors and MBIA, and any material changes to these Codes. The
Board shall approve any material change to a Code no later than six (6) months
after the adoption of the material change.
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Before approving any code of ethics or any amendment to such
code, the Board shall have received a certification from the Trust or Fund, as
the case may be, 1838 Advisors and MBIA that it has adopted procedures
reasonably necessary to prevent Access Persons from violating 1838 Advisors' or
MBIA's Code of Ethics.
Dated: _______________, 2000
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APPENDIX A
SERIES OF 1838 INVESTMENT ADVISORS FUNDS
1838 International Equity Fund
1838 Fixed Income Fund
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APPENDIX B
SUMMARY OF RULE 17J-1(B)
It shall be unlawful for
o any affiliated person of, or principal underwriter for, a registered
investment company, or
o any affiliated person of an investment adviser of, or principal
underwriter for, a registered investment company
in connection with the purchase or sale, directly or indirectly, by such person
of a security held or to be acquired [SEE NOTE BELOW] . . . by such registered
investment company:
(1) to employ any device, scheme or artifice to defraud such registered
investment company;
(2) to make to such registered investment company
o any untrue statement of a material fact or
o omit to state to such registered investment company a material
fact necessary in order to make the statements made, in light
of the circumstances under which they are made, not
misleading;
(3) to engage in any act, practice, or course of business which operates or
would operate as a fraud or deceit upon any such registered investment
company; or
(4) to engage in any manipulative practice with respect to such registered
investment company.
NOTE:
For purposes of Rule 17j-1, a "security held or to be acquired" by a registered
investment company means"
(i) any Covered Security within the meaning of the Rule (see the
definition of the term "Covered Security" in Appendix C to
this Code) which, within the most recent fifteen (15) calendar
days:
o is or has been held by the investment company; or
o is being or has been considered by such company, or
its investment adviser, for purchase by the company
(ii) any option to purchase or sell, and any security convertible
into or exchangeable for, a Covered Security described above.
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APPENDIX C
Definitions of Terms Used Within The Joint Code of Ethics
(a) "Access Person" means:
(i) Any director, trustee, officer, general partner or
Advisory Person of the Trust, the Fund or of 1838
Advisors.
(ii) Any director, officer, or general partner of MBIA
who, in the ordinary course of business, makes,
participates in or obtains information regarding the
purchase or sale of Covered Securities by the Trust,
or whose functions relate to the making of any
recommendations to the Trust regarding the purchase
or sale of Covered Securities.
(b) "Advisory Person" means
(i) any employee of the Trust, Fund or 1838 Advisors (or
of any company in a control relationship to the
Trust, Fund or 1838 Advisors) who, in connection with
his regular functions or duties, makes, participates
in, or obtains current information regarding the
purchase or sale of a Covered Security by the Trust
or Fund, or whose functions relate to the making of
any recommendations with respect to such purchases or
sales; and
(ii) any natural person in a control relationship to the
Trust, Fund or 1838 Advisors, who obtains information
concerning recommendations made to the Trust or Fund
with regard to the purchase or sale of a Covered
Security by the Trust or Fund.
(c) A security is "being considered for purchase or sale" or is
"being purchased or sold" when a recommendation to purchase or
sell the security has been made and communicated to the
Trading Desk, which includes when the Trust or Fund has a
pending "buy" or "sell" order with respect to a security, and,
with respect to the person making the recommendation, when
such person seriously considers making such a recommendation.
(d) "Beneficial ownership" shall be as defined in, and interpreted
in the same manner as it would be in determining whether a
person is subject to the provisions of, Section 16 of the
Securities Exchange Act of 1934 and the rules and regulations
thereunder which, generally speaking, encompasses those
situations where the beneficial owner has the right to enjoy
some economic benefit from the ownership of the security
regardless of who is the registered owner. This would include:
(i) securities which a person holds for his or her own
benefit either in bearer form, registered in his or
her own name or otherwise regardless of whether the
securities are owned individually or jointly;
(ii) securities held in the name of a member of his or her
immediate family (spouse, minor child and adults)
sharing the same household;
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(iii) securities held by a trustee, executor,
administrator, custodian or broker;
(iv) securities owned by a general partnership of which
the person is a member or a limited partnership of
which such person is a general partner;
(v) securities held by a corporation which can be
regarded as a personal holding company of a person;
and
(vi) securities recently purchased by a person and
awaiting transfer into his or her name.
(e) "Compliance Officer" means the officer or employee of the
Trust or Fund, as the case may be, who is authorized and
appointed by the Trust or Fund to perform, or procure the
performance of, the various responsibilities assigned to such
Compliance Officer by this Code.
(f) "Control" has the same meaning as that set forth in Section
2(a)(9) of the Act.
(g) "Covered Security" means a security as defined in Section
2(a)(36) of the Act, except that it shall not include
(i) direct obligations of the Government of the United
States;
(ii) bankers' acceptances, bank certificates of deposit,
commercial paper and high quality short-term debt
instruments, including repurchase agreements; and
(iii) shares issued by registered open-end investment
companies.
(h) "Independent Trustee" and "Independent Director" means a
Trustee of the Trust and Director of the Fund, respectively,
who is not an "interested person" of the Trust or Fund,
respectively, within the meaning of Section 2(a)(19) of the
Act.
(i) "Initial Public Offering" ("IPO") means an offering of
securities registered under the Securities Act of 1933
("Securities Act"), the issuer of which, immediately before
the registration, was not subject to the reporting
requirements of Sections 13 or 15(d) of the Securities
Exchange Act of 1934.
(j) "Investment Personnel" means:
(i) any employee of the Trust, the Fund, or 1838 Advisors
(or of any company in a control relationship to the
Trust, the Fund or 1838 Advisors), who, in connection
with his regular functions or duties, makes or
participates in making recommendations regarding the
purchase or sale of securities by the Trust or the
Fund; and
(ii) any natural person who controls the Trust, the Fund,
or 1838 Advisors and who obtains information
concerning recommendations made to the Trust or Fund
regarding the purchase or sale of securities by the
Trust or Fund.
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(k) "Limited Offering" means an offering that is exempt from
registration under the Securities Act pursuant to Section 4(2)
or Section 4(6) or pursuant to Rule 504, Rule 505 or Rule 506
under the Securities Act.
(l) "Purchase or Sale of a Covered Security" includes the writing
of an option to purchase or sell a Covered Security.
(m) "Security Held or to be Acquired" by the Trust or Fund means:
(i) any Covered Security which, within the most recent
fifteen (15) days:
(A) is or has been held by the Trust or Fund; or
(B) is being or has been considered by the
Trust, Fund or 1838 Advisors for purchase by
the Trust or the Fund; and
(ii) any option to purchase or sell, and any security
convertible into or exchangeable for, a Covered
Security described in paragraph (m)(i) of this
section.
(n) "Security" as defined in Section 2(a)(36) of the Act means any
note, stock, treasury stock, bond, debenture, evidence of
indebtedness, certificate of interest or participation in any
profit-sharing agreement, collateral-trust certificate,
preorganization certificate or subscription, transferable
share, investment contract, voting-trust certificate,
certificate of deposit for a security, fractional undivided
interest in oil, gas, or other mineral rights, any put, call,
straddle, option, or privilege on any security (including a
certificate of deposit) or on any group or index of securities
(including any interest therein or based on the value
thereof), or any put, call, straddle, option, or privilege
entered into in a national securities exchange relating to
foreign currency, or, in general, any interest or instrument
commonly known as a "security," or any certificate of interest
or participation in, temporary or interim certificate for,
receipt for, guarantee of, or warrant or right to subscribe to
or purchase, any of the foregoing.
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APPENDIX D
1838 INVESTMENT ADVISORS FUNDS
1838 BOND-DEBENTURE TRADING FUND
1838 INVESTMENT ADVISORS, LLC
MBIA CAPITAL MANAGEMENT CORPORATION
JOINT CODE OF ETHICS
INITIAL HOLDINGS REPORT
To the Compliance Officer of 1838 Investment Advisors Funds, 1838 Bond-Debenture
Trading Fund, 1838 Investment Advisors, LLC or MBIA Capital Management
Corporation.
1. I hereby acknowledge receipt of a copy of the Joint Code of
Ethics for 1838 Investment Advisors Funds (the "Trust") and 1838 Bond-Debenture
Trading Fund (the "Fund").
2. I have read and understand the Code and recognize that I am
subject thereto in the capacity of an "Access Person."
3. Except as noted below, I hereby certify that I have no
knowledge of the existence of any personal conflict of interest relationship
which may involve the Trust or Fund, such as any economic relationship between
my transactions and securities held or to be acquired by the Trust or any of its
series, or by the Fund.
4. As of the date below I had a direct or indirect beneficial
ownership interest in the following securities:
Type of Interest
Name of Securities Number of Shares (Direct or Indirect)
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5. As of the date below, the following is a list of all
brokers, dealers or banks with whom I maintain an account in which securities
are held for my direct or indirect benefit:
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Type of Interest
Firm Account (Direct or Indirect)
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Date:
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Print Name:
-------------------------
Title:
-------------------------
Employer's Name:
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1838 INVESTMENT ADVISORS FUNDS
1838 BOND-DEBENTURE TRADING FUND
1838 INVESTMENT ADVISORS, LLC
MBIA CAPITAL MANAGEMENT CORPORATION
JOINT CODE OF ETHICS
ANNUAL HOLDINGS REPORT
To the Compliance Officer of 1838 Investment Advisors Funds (the "Trust"), 1838
Bond-Debenture Trading Fund (the "Fund"), 1838 Investment Advisors, LLC, or MBIA
Capital Management Corporation.
1. I have read and understand the Joint Code of Ethics and
recognize that I am subject thereto in the capacity of an "Access Person."
2. I hereby certify that, during the year ended December 31,
___, I have complied with the requirements of the Code and I have reported all
securities transactions required to be reported pursuant to the Code.
3. Except as noted below, I hereby certify that I have no
knowledge of the existence of any personal conflict of interest relationship
which may involve the Trust or Fund, such as any economic relationship between
my transactions and securities held or to be acquired by the Trust or any of its
Series, or by the Fund.
4. As of December 31, _____, I had a direct or indirect
beneficial ownership interest in the following securities:
Type of Interest
Name of Securities Number of Shares (Direct or Indirect)
- ------------------ ---------------- --------------------
5. As of December 31, ___, the following is a list of all
brokers, dealers, or banks with whom I maintain an account in which securities
are held for my direct or indirect benefit:
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Type of Interest
Firm Account (Direct or Indirect)
- ---- ------- --------------------
Date:
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Print Name:
-------------------------
Title:
-------------------------
Employer's Name:
-------------------------
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1838 INVESTMENT ADVISORS FUNDS
1838 BOND-DEBENTURE TRADING FUND
1838 INVESTMENT ADVISORS, LLC
MBIA CAPITAL MANAGEMENT CORPORATION
Securities Transactions Report
For the Calendar Quarter Ended:______________
To the Compliance Officer of 1838 Investment Advisors Funds ("the Trust"), 1838
Bond-Debenture Trading Fund (the "Fund"), 1838 Investment Advisors, LLC, or MBIA
Capital Management:
During the quarter referred to above, the following
transactions were effected in securities of which I had, or by reason of such
transaction acquired, direct or indirect beneficial ownership, and which are
required to be reported pursuant to the Joint Code of Ethics adopted by the
Trust and the Fund.
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SECURITY
(INCLUDING BROKER/DEALER
INTEREST RATE AND NATURE OF OR BANK
MATURITY DATE, IF DATE OF DOLLAR AMOUNT TRANSACTION THROUGH WHOM
APPLICABLE) TRANSACTION NO. OF SHARES OF TRANSACTION (PURCHASE, SALE, OTHER) PRICE EFFECTED
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During the quarter referred to above, the following accounts
were established by me in which securities were held for my direct or indirect
benefit:
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FIRM NAME
(BROKER, DEALER OR BANK) DATE ACCOUNT WAS ESTABLISHED ACCOUNT NUMBER
- -------------------------------------------------------------------------------
- -------------------------------------------------------------------------------
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This report (i) excludes transactions with respect to which I
had no direct or indirect influence or control, (ii) excludes other transactions
not required to be reported, and (iii) is not an admission that I have or had
any direct or indirect beneficial ownership in the securities listed above.
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Except as noted on the reverse side of this report, I hereby
certify that I have no knowledge of the existence of any personal conflict of
interest relationship which may involve the Trust or Fund, such as the existence
of any economic relationship between my transactions and securities held or to
be acquired by the Trust or any of its Series, or by the Fund.
Type of Interest
Firm Account (Direct or Indirect)
- ---- ------- --------------------
Date:
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Print Name:
-------------------------
Title:
-------------------------
Employer's Name:
-------------------------
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