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March, 2000
PERSONAL SECURITIES TRADING
POLICIES AND PROCEDURES
For: Deutsche Funds Management, Inc. (DFM)
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I. INTRODUCTION
DFM ("Asset Management") recognize the desirability of permitting
Employees and members of their immediate families the opportunity to engage in
normal investment practices for their personal accounts and accounts in which
they have a beneficial interest. The legitimate investment objectives of
Employees, however, must be balanced against the interests of clients as well as
Asset Management's regulatory responsibilities.
Asset Management's policies and procedures regarding personal
securities trading have been developed in response to various securities laws
and rules and regulations of self-regulatory agencies. These procedures include
many of the recommendations made by a special advisory group formed by the
Investment Company Institute to review practices and standards governing
personal investing. These procedures have been submitted to the Board of
Directors of the Flag Investors Family of mutual funds (the "Funds"), and shall
serve as the Code of Ethics required in connection with Asset Management's
services as investment advisor to the Funds.
Each Employee is expected to adhere to these policies and procedures
so as to avoid any actual or potential conflicts of interest, or situations in
which an individual may be accused of having abused a position of trust and
responsibility. Any questions regarding the application of these policies and
procedures should be directed to your appropriate senior officer or the
designated Asset Management compliance officer.
II. DEFINITIONS
EMPLOYEE - For purposes of these policies and procedures, the term Employee
will refer to all Employees of Asset Management and members of their
immediate families.
IMMEDIATE FAMILY - Immediate Family shall include spouse, minor children,
dependents and other relatives who share the same house and depend on the
Employee for support.
EMPLOYEE RELATED ACCOUNTS - The term " Employee Related Account" shall mean
any account held in the name of an Employee or in which the Employee has a
Beneficial Interest. In addition, such accounts include accounts held in
the name(s) of any
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member(s) of the Employee's Immediate Family as well as any account in
which those persons have a Beneficial Interest.
BENEFICIAL INTEREST - An Employee or immediate family member shall be
considered to have a beneficial interest in an account if he or she obtains
benefits from the account substantially equivalent to whole or partial
ownership. Employee and immediate family members are also deemed to have a
beneficial interest in accounts in which they have the power, directly or
indirectly, to make investment decisions. Examples include, but are not
limited to, accounts for trusts, partnerships and corporations in which an
Employee or immediate family member maintains an interest or derives a
benefit.
DISCRETIONARY ACCOUNTS - An Employee Related Account where full investment
discretion has been granted to an investment manager, trustee or outside
bank where neither the Employee nor a close relative participates in the
investment decisions or is informed in advance of transactions in the
account.
III. POLICIES/PROCEDURES
A. SUBSTANTIVE RESTRICTIONS ON PERSONAL INVESTING
1. Initial Public Offerings
Asset Management Employees are prohibited from acquiring shares
of an issuer in an initial public offering.
2. Private Securities Transactions
Asset Management Employees may engage in such transactions after
having obtained the prior written approval of the appropriate
senior officer of their respective business unit and Mutual Funds
Compliance. Attached as EXHIBIT A is a copy of the general policy
and the appropriate form for making such request. Among the
factors in considering the request by a senior officer are: 1)
whether the opportunity is being made available to the Employee
due to the Employee's position within Asset Management; 2)
whether the transaction would appear to conflict with clients'
interests; and, 3) whether the security being offered is an
appropriate investment to be made on behalf of clients.
Employees who received approval to engage in a private securities
transaction must disclose that investment in the event they
become involved in any subsequent consideration of the issuer as
a potential investment for the Funds or other clients. In such
circumstances, a final decision to invest on behalf of clients
should be made after independent review by personnel with no
personal interest in the issuer.
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3. Blackout Periods
a. PENDING TRADES - Employees are prohibited from executing a
transaction in an Employee Related Account when Asset
Management clients of their respective business unit have
pending "buy" or "sell" orders in the same security. This
prohibition will remain in effect until such orders are
executed or withdrawn.
b. FUND TRADES - Employees are prohibited from trading in a
security for a period of at least seven calendar days
before, and three calendar days after, any transaction by a
Fund Account advised by that respective business unit of
Asset Management in the same security. This blackout period
would be inapplicable where 1) the market capitalization of
the security exceeded $2 billion; and 2) trades of the
respective business unit of Asset Management do not exceed
10% of the daily average trading volume for the prior 15
days.
c. DISCRETIONARY ACCOUNTS - The Blackout Periods described
above do not apply to Discretionary Accounts.
4. Outside Securities Accounts
a. GENERAL
Except in extraordinary circumstances, Asset Management
prohibits the maintenance of Employee Related Accounts with
broker/dealers outside of DBAB. The appropriate senior
officer for their respective business units must approve any
requests by Employees for such accounts. Attached as EXHIBIT
B, is a copy of the general policy and the appropriate form
for making such request. All such accounts are subject to
prior approval and record keeping requirements as will be
described below.
b. EXCEPTIONS
Asset Management has determined that the following outside
accounts are exempt from the prior approval requirements:
(i) accounts maintained directly with an investment company
in which shares of open-end investment companies ONLY
can be purchased; and
(ii) Discretionary Accounts.
c. TRANSFER
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Outside accounts which are not exempt under Section 4.b.
must be transferred to DBAB within forty-five (45) days of
the Employee's hire date.
5. Ban on Short-Term Trading Profits
In addition to the blackout periods noted above, and in the
absence of appropriate extenuating circumstances, Asset
Management Employees are prohibited from profiting in the
purchase and sale, or sale and purchase, of the same (or
equivalent) securities within 60 calendar days. Profits realized
from trades within the proscribed period will be required to be
forfeited to the appropriate Asset Management business unit.
Under limited and appropriate circumstances, an Employee may
request an exception to this restriction. Such requests may only
be made to the appropriate senior officer of his or her
respective business unit.
6. Outside Business Affiliations, Employment or Compensation
Asset Management Employees may not maintain outside affiliations
(e.g. officer or director, governor, trustee, etc.) without the
prior written approval of the appropriate senior officer of their
respective business units. Attached as EXHIBIT C is a copy of the
general policy and the appropriate form for making such request.
Service on Boards of publicly traded companies should be limited
to a small number of instances. However, such service may be
undertaken based upon a determination that these activities are
consistent with the interest of Asset Management and its clients.
Employees serving as directors will not be permitted to
participate in the process of making investment decisions on
behalf of clients which involve the subject company.
7. Gifts
Asset Management restricts the making or receiving of gifts and
gratuities to ensure the highest standards of employee integrity
and conduct, and to ensure compliance with rules of the various
self-regulatory organizations. Asset Management Employees are
expected to report and receive prior approval for any such gifts
or gratuities, except for gifts of DE MINIMIS value. DE MINIMIS
is defined as the annual receipt of gifts from the same source
valued at $100 or less.
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B. PROCEDURES FOR PERSONAL INVESTING
1. Transaction Approval
All Asset Management Employees must receive prior approval
of personal securities transactions in Employee Related
Accounts. All prior approval requests must be made in
writing to the appropriate person designated for such
approvals. Approvals of transactions are good for the day
they are given and must be reinstated the next day if not
executed or withdrawn. Attached as EXHIBIT D is a copy of
the Personal Securities Transaction Approval Form to be
completed by Asset Management Employees. Only after
receiving approval may the Asset Management Employees
contact their registered representative to enter the order.
Requests for approval of trades by DFM Employees (and the
accompanying approval form) are to be directed to Mutual
Funds Compliance. After approval, DFM employees must receive
approval from Corporate Compliance and forward the Corporate
pre-clearance number to Mutual Funds Compliance. One copy of
the completed form will be maintained with Mutual Funds
Compliance.
Asset Management has determined that certain securities
transactions are exempt from the prior approval requirements
as follows:
- Trading activity in Discretionary Accounts;
- Shares of open-end investment companies
registered under the Investment Company Act
of 1940;
- Shares purchased under an issuer sponsored
dividend reinvestment program;
- Purchases and sales of securities issued or
guaranteed by the U.S. government or its
agencies and bank certificates of deposit;
- To the extent acquired from the issuer,
purchases effected upon the exercise of
rights issued PRO RATA to holders of a class
of securities; and
- Securities purchased under an employer
sponsored stock purchase plan or upon the
exercise of employee stock options. ANY SALE
OF SECURITIES ACQUIRED PURSUANT TO THE
EXERCISE OF EMPLOYEE STOCK OPTIONS REMAINS
SUBJECT TO THE PRE-CLEARANCE PROCEDURES.
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2. Records of Securities Transactions
a. GENERAL
Each Asset Management Employee is responsible for confirming
that all Employee Related Accounts are set up in such a way
that designated supervisory personnel receive records of
securities transactions as follows:
(i) In the case of accounts maintained at DBAB, a report
system (the Firm Insider Trade Report System) has been
developed which will provide designated supervisory
personnel a monthly summary report of securities
transactions in Employee Related Accounts. At the time
an account is approved, Employees must provide the
account name and number to the person in their
respective business unit responsible for maintaining
the report system.
(ii) In the case of outside securities accounts, Asset
Management must receive duplicate copies of
confirmations and statements. Before engaging in any
transactions, the Employee must confirm that: i) the
account has been approved; and, ii) that firm has been
instructed to provide duplicate confirmations and
statements.
b. EXEMPTIONS
(i) Accounts maintained directly with an investment company
in which shares of open-end investment companies ONLY
can be purchased are exempt from the records
requirements, provided that the requisite information
regarding the account is disclosed in the Employee's
Initial Holdings Report and Annual Holdings Report, as
described in paragraph 4.a. below.
(ii) Discretionary Accounts are exempt from the records
requirements, provided that the requisite information
regarding the account is disclosed as described in
paragraph 4.b. below.
3. Post-Trade Monitoring
Asset Management supervisory personnel will conduct periodic
reviews of the trading activities of Asset Management Employees
to monitor compliance with these procedures so as to ensure that
the interests of Asset Management and its clients are not
compromised.
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4. Certification/Disclosure of Accounts and Holdings
a. EMPLOYEE RELATED ACCOUNTS
All Asset Management Employees will, at time of hire and
annually thereafter, be provided with a copy of these
policies and procedures and will be requested to certify
annually that they have read and understand them.
(i) INITIAL HOLDINGS REPORT
Within 10 days of the Employee's hire date, each
Employee shall make an Initial Holdings Report in the
form of EXHIBIT E.
(ii) ANNUAL HOLDINGS REPORT
On an annual basis, each Employee shall make an
Annual Holdings Report in the form of EXHIBIT E. The
Annual Holdings Report shall contain information
which is current as of a date which is no more than
30 days before the report is submitted.
b. DISCRETIONARY ACCOUNTS
Each Asset Management Employee with an outside Discretionary
Account will, at the time of hire and annually thereafter,
provide Mutual Funds Compliance with a certification from
their investment manager, trustee or outside bank, as
applicable, as to the discretionary status of the account.
The certification form is attached as EXHIBIT F.
C. SANCTIONS
Persons violating the provisions of these Personal Trading
Policies and Procedures may be subject to the following
sanctions:
1. Upon the first violation within a one-year period, the
Employee will be subject to a monetary penalty of $100,
or such other penalty as may be determined in the
discretion of the committee referenced in paragraph 3.
2. Upon the second violation within a one-year period, the
Employee will be subject to a monetary penalty of $500,
or such other penalty as may be determined in the
discretion of the committee referenced in paragraph 3
(assuming that the first violation was brought to the
Employee's attention).
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3. Upon the third violation within a one-year period, the
matter shall be reviewed by a committee consisting of
the Head of the Business Unit, the Head of Legal and
the Head of Compliance. The committee will determine
appropriate sanctions, which may include (but are not
limited to) a letter of censure, further monetary
penalties, restrictions on the violator's personal
securities transactions, unwinding of the transaction
and disgorgement of profits and suspension or
termination of employment.
The proceeds of any monetary penalties recovered in
connection with the sanctions described above shall be
donated to the United Way.
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EXHIBIT A
PRIVATE SECURITIES TRANSACTIONS
Private Securities Transactions are those which are not transacted
through a brokerage firm and/or not reflected on records of accounts maintained
at such brokerage firms. Asset Management Employees and members of their
immediate family may not purchase or sell any security (except those exempt
under these Personal Securities Policies and Procedures) in a private securities
transaction unless the Employee has received the PRIOR WRITTEN APPROVAL of the
senior officer of their respective business unit. Requests for approval must be
made on the REQUEST FOR APPROVAL OF PRIVATE SECURITIES TRANSACTION FORM (a copy
of which is provided with this Code).
The definition of a private securities transaction should be construed
broadly. Any questions regarding such transactions should be directed to the
senior officer of the respective business unit.
PLEASE SEE THE REQUEST FOR APPROVAL OF PRIVATE SECURITIES
TRANSACTION FORM BEGINNING ON THE FOLLOWING PAGE
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REQUEST FOR APPROVAL OF
PRIVATE SECURITIES TRANSACTION
To:__________________________________________________(Branch/Department Manager)
The undersigned requests approval of the following securities transaction:
Issuer:_________________________________________________________________________
Is Issuer a publicly traded company? Yes ______ No ______
Buy: ______ Sell: ______ Anticipated Date of Transaction: __________________
Description of Securities: _____________________________________________________
Number of Shares/Units: ____________________________ Cost/Proceeds ____________
Name of person from whom I propose to purchase or to whom I propose to sell:
________________________________________________________________________________
Is this person a client of the Firm? Yes ______ No ______
If yes, what is nature of the client relationship between that person and the
firm?
________________________________________________________________________________
To your knowledge, is this investment being offered to others? Yes ____ No ____
Are you providing any service or advice to this Issuer? Yes ____ No ____
If yes, please describe the service or advice: _________________________________
________________________________________________________________________________
____________________________________
(Name of Person Requesting Approval)
_________________________________ ____________________________________
(Date) (Signature)
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IMPORTANT NOTICE
IT IS THE FIRM'S POLICY THAT EMPLOYEES MAY NOT SOLICIT OR RECOMMEND TO
ANY CLIENT OF THE FIRM THE PURCHASE OF ANY SECURITY UNLESS SUCH PURCHASE IS MADE
THROUGH THE FIRM. MOREOVER, THE RECEIPT BY ANY EMPLOYEE OF A "FINDER'S FEE" OR
OTHER COMPENSATION FROM A PERSON OR COMPANY UNRELATED TO THE FIRM FOR REFERRALS
OF PROSPECTIVE INVESTORS IS PROHIBITED.
To: Mutual Funds Compliance
I have reviewed and approved this request for permission to engage in
the private securities transaction described. In connection with this request, I
have the following comments:
________________________________________________________________________________
________________________________________________________________________________
________________________________________________________________________________
________________________________________
(Name of Branch/Department Manager)
__________ ________________________________________
(Date) (Signature of Branch/Department Manager)
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To: _______________________________________________ (Person Requesting Approval)
Your request for permission to engage in the private securities
transaction described on the front of this form has been APPROVED. If any of the
details of that transaction change, please advise Mutual Funds Compliance BEFORE
the transaction is completed.
________________________ _______________________________
(Date) (Mutual Funds Compliance)
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EXHIBIT B
OUTSIDE SECURITIES ACCOUNTS
It is the Firm's policy that all Employee Related Accounts be
maintained at DBAB. Such accounts may be maintained at outside firms only in
extraordinary circumstances. Any such requests for an outside securities account
must be made in writing on a REQUEST FOR APPROVAL OF AN OUTSIDE BROKERAGE
ACCOUNT FORM (a copy of which is provided with these procedures) and approved IN
ADVANCE by the appropriate senior officer of the respective business unit.
Approval will be granted only if:
|_| The other firm offers products of services not available through
DBAB; or,
|_| Other extenuating needs or circumstances exist and are demonstrated.
PLEASE SEE THE REQUEST FOR APPROVAL OF OUTSIDE BROKERAGE
ACCOUNT FORM BEGINNING ON THE FOLLOWING PAGE
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REQUEST FOR APPROVAL OF AN OUTSIDE BROKERAGE ACCOUNT
To: ____________________________________ From: ______________________________
Branch/Department Manager
The undersigned requests approval to maintain the outside brokerage account
described below.
Name & Address ______________________________________________________________
of Broker Dealer ______________________________________________________________
Investment Representative for A/C: ___________________________________________
A/C #: _______________________ A/C Title: _____________________________________
Reason for Request: ____________________________________________________________
_______________________________________________________________________________
_______________________________________________________________________________
I understand that if my request is approved, I must:
1) Comply with the Firm's procedures requiring prior approval by my
supervisor of All transactions in this account; and
2) Make the necessary arrangements for my supervisor to receive
duplicate confirmations and monthly statements for this account.
_____________________________________ _________________________________________
(Name of Person Requesting Approval) (Signature of Person Requesting Approval)
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To: Mutual Funds Compliance Date: _________________________
I have reviewed and approved this request for the above outside
brokerage account.
_____________________________________ ________________________________________
(Name of Branch/Department Manager) (Signature of Branch/Department Manager)
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EXHIBIT C
OUTSIDE BUSINESS AFFILIATIONS,
EMPLOYMENT AND COMPENSATION
GENERAL POLICY
No Asset Management Employee may maintain outside affiliations
(directorships, governorships or trusteeships) with business organizations,
outside employment or receive compensation from any source, without the PRIOR
APPROVAL of the senior officer of their respective business unit. In addition,
some instances may require approval by the New York Stock Exchange as well.
Requests for approval must be made on the OUTSIDE BUSINESS AFFILIATION,
EMPLOYMENT OR COMPENSATION FORM (a copy of which is provided with these
procedures). Termination of such affiliations must also be reported.
SERVICE ON BOARD OF ELEEMOSYNARY ORGANIZATIONS
Asset Management Employees are encouraged not only to provide monetary
support to charitable and civic organizations in their communities, but also to
be generous with their time and effort. Asset Management is justifiably proud
that many Employees serve as officers, directors, trustees or fund-raisers for
numerous eleemosynary organizations.
From time to time, such organizations may need to procure, either
directly or indirectly, brokerage or investment management services that DBAB
provides, and the Employee associated with such an organization may expect
either to provide those services on behalf of DBAB, or be compensated by DBAB as
a result of the use of these services, or to be directed business by an
unrelated service provider recommended by the Employee to that organization.
For the benefit of the eleemosynary organization, DBAB and the Asset
Management Employee associated with the eleemosynary organization, the following
guidelines apply WHENEVER DBAB is providing or is expected to provide services,
directly or indirectly, to the organization with which the employee is
associated:
1. The Employee must disclose his or her employment by DBAB; and,
2. If the Employee expects to be compensated by DBAB in
connection with or as a result of, the services provided by
DBAB or an unrelated service provider recommended by the
Employee, the Employee must disclose this fact; and,
3. If the Employee is a member of the body which decides whether
to employ DBAB, the Employee must abstain from participating
in the selection of the service provider; and,
4. All of the foregoing must be memorialized in writing to the
appropriate officer of the board of the eleemosynary
organization or in the minutes of the applicable meeting(s) of
the governing body at which the selection of the service
provider is made.
PLEASE SEE THE APPROVAL OF OUTSIDE BUSINESS AFFILIATION,
EMPLOYMENT OR COMPENSATION FORM ON THE FOLLOWING PAGE
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OUTSIDE BUSINESS AFFILIATION, EMPLOYMENT OR COMPENSATION
FIRM POLICY
No Employee may maintain any outside affiliations (e.g. officer or
director, governor, or trustee etc.) with any business organization, outside
employment, or receive compensation from any source without prior approval of
the individual's Branch/Department Manager and Mutual Funds Compliance.
Outside affiliation relationships with non-business organizations (e.g.
church, civic organization, etc.) do not require prior approval unless the
Employee wants to establish and handle an account for the organization.
Generally, Employee's may not serve as trustee for any such accounts while they
also serve as IR.
Please provide the information requested below, sign on the back, and
submit the form to you Branch/Department Manager for approval. You will be
informed if approval is granted.
1. Employee Name: _____________________________________________________________
2. Organization with which you wish to become affiliated, or organization or
person by whom you wish to be employed or compensated:
a. Name: ________________________________________________________________
b. Address: _____________________________________________________________
c. Nature of Business: __________________________________________________
d. Does the organization have publicly traded securities? _______________
e. If so, where are they traded? ________________________________________
f. Does the organization have a brokerage account at the Firm? __________
g. If so, what is the account number and who is the IR? _________________
3. State the nature of your proposed affiliation or employment, or the nature
of the services for which you will be compensated, and briefly describe
your duties: ______________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
4. On what date will your proposed affiliation, employment or compensation
begin? ____________________________________________________________________
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5. a. Will you be compensated? _____________________________________________
b. If so, how much? _____________________________________________________
6. State the nature and extent of your financial interest, if any, in the
organization:
___________________________________________________________________________
___________________________________________________________________________
7. State the amount of time you will devote to the organization's business and
indicate whether you will devote any time to the organization's business
during normal working hours:
___________________________________________________________________________
8. State the reasons why you have been asked to become affiliated with the
organization (social contact, knowledge of the industry,
etc.)______________________________________________________________________
___________________________________________________________________________
___________________________________________________________________________
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To: ____________________________________________ (Branch/Department Manager)
The undersigned requests approval of the outside business affiliation,
employment or compensation described on the reverse side of this request.
__________________________________________
(Name of Person Requesting Approval)
___________ __________________________________________
(Date) (Signature of Person Requesting Approval)
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To: Mutual Funds Compliance
I have reviewed and approved this request for the outside business
affiliation, employment or compensation described on the reverse side of this
request. In connection with this request, I have the following comments:
________________________________________________________________________________
________________________________________________________________________________
__________________________________________
(Name of Branch/Department Manager)
_________ __________________________________________
(Date) (Signature of Branch/Department Manager)
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To: ____________________________________ (Person Requesting Approval)
The outside business affiliation, employment or compensation described
on the reverse side of this request has been APPROVED. Please advise your
Manager and the Legal/Compliance Department in writing if any of the information
on the reverse side of this request changes materially.
____________________ _________________________________
(Date) (Mutual Funds Compliance)
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EXHIBIT D
DFM EMPLOYEE TRANSACTION APPROVAL FORM
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EMPLOYEE NAME
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NAME OF SECURITY
--------------------------------------------------------------------------------
BUY OR SELL/ # OF SHARES
--------------------------------------------------------------------------------
TRADE DATE
--------------------------------------------------------------------------------
ACCOUNT #
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BROKER / BROKERAGE
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ARE YOU AWARE OF ANY FUND TRADES OF THE SECURITIES NAMED ABOVE IN THE PAST 3
DAYS OR OF THE INTENTION OF ANY FUND MANAGER TO TRADE THE SECURITIES NAMED ABOVE
WITHIN THE NEXT 7 DAYS? / / YES / / NO
IF THE TRANSACTION DESCRIBED ABOVE IS A PURCHASE, DOES IT INVOLVE THE
ACQUISITION OF SHARES OF AN ISSUER IN AN INITIAL PUBLIC OFFERING? / / YES / / NO
(PURCHASES OF SHARES OF AN ISSUER IN AN INITIAL PUBLIC OFFERING ARE PROHIBITED.)
IF THE TRANSACTION DESCRIBED ABOVE IS A TRANSACTION FOR PROFIT, HAVE YOU HELD
YOUR POSITION IN THE SECURITIES FOR MORE THAN 60 DAYS? / / YES / / NO
(IF TRANSACTION IS FOR PROFIT, POSITION MUST BE HELD A MINIMUM OF SIXTY (60)
DAYS PRIOR TO SALE.)
APPROVAL ___________________________
Corporate Compliance 212-469-8787 CORPORATE PRE-CLEARANCE # __________
________________________________________________________________________________
FOR COMPLIANCE DEPARTMENT USE ONLY
----------------------------------
-Market cap: ____ over $2 billion ____ under $2 billion
-Fund trades do not exceed 10% of Issuer's average daily trading volume for last
15 days: ____ yes ____ no
-Blackout period applies: ____ yes ____ no
_____ Initials
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EXHIBIT E
DEUTSCHE FUNDS MANAGEMENT, INC.
INITIAL/ANNUAL HOLDINGS REPORT
NAME: ________________________
DATE: ________________________
I hereby certify that I have read, understand and have complied with the
memorandum entitled: PERSONAL SECURITIES TRADING POLICIES AND PROCEDURES.
Furthermore, I am providing/confirming below certain additional information.
IF MORE SPACE IS NEEDED, ATTACH AN ADDITIONAL FORM
1. Provided below is a description of ALL Employee Related Accounts (including
open-end investment company accounts), as described in these procedures,
which I maintain or in which I have a beneficial interest.
PLEASE ATTACH A COPY OF THE MOST RECENT STATEMENT FOR
ALL ACCOUNTS LISTED
ACCOUNT NAME ACCOUNT NUMBER BROKER/DEALER OR BANK
AT WHICH MAINTAINED
__________ ______________ _____________________
__________ ______________ _____________________
__________ ______________ _____________________
__________ ______________ _____________________
__________ ______________ _____________________
__________ ______________ _____________________
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2. Provided below is a description of securities in which I have any direct or
indirect beneficial interest.
NAME OF CLASS SHARE/ PRINCIPAL AMOUNT
ISSUER OF SECURITIES UNIT (IF DEBT SECURITY)
AMOUNT
_________ _____________ ______ ___________________
_________ _____________ ______ ___________________
_________ _____________ ______ ___________________
_________ _____________ ______ ___________________
_________ _____________ ______ ___________________
_________ _____________ ______ ___________________
3. I have engaged in the following private securities transactions during the
calendar year.
NAME OF ISSUER DATE OF TRANSACTION NATURE OF INVESTMENT
____________ _________________ _____________________
____________ _________________ _____________________
____________ _________________ _____________________
____________ _________________ _____________________
____________ _________________ _____________________
____________ _________________ _____________________
________________ ___________________________
(Date) (Signature)
________________________________________________________________________________
FOR COMPLIANCE DEPARTMENT USE ONLY
Reviewed by:
Name: ______________________________
Signature: ___________________________
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EXHIBIT F
DISCRETIONARY ACCOUNT CERTIFICATION FORM
I, ____________________ hereby certify that I am a representative of
the investment manager, trustee or outside bank at which the account described
below is maintained:
ACCOUNT NAME: ___________________________________________
ACCOUNT NUMBER: ___________________________________________
FIRM AT WHICH
MAINTAINED: ___________________________________________
BENEFICIARY(IES): ___________________________________________
I further certify that neither the Beneficiary named above nor any
close relative of the Beneficiary exercises investment discretion over the
account, participates in investment decisions with respect to the account or is
informed in advance of transactions in the account.
----------------------------------
(Signature)
----------------------------------
(Name)
----------------------------------
(Title)
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