<PAGE> 1
NYLIFE DISTRIBUTORS, INC.
CODE OF ETHICS
This Code of Ethics (the "Code") has been issued by NYLIFE Distributors,
Inc.(the "Corporation" or the "Company") in order to set forth applicable
guidelines and procedures that promote ethical practices and conduct by all of
its employees.1 All recipients of the Code are to read it carefully, retain it
for future reference and abide by its requirements. Also, please refer to the
Corporation policy entitled, "Personal Investment Policy," which has been
incorporated into the Code and is an integral part of its requirements. The
Personal Investment Policy will provide each employee with specific guidance
concerning personal security investments and the responsibilities associated
with that activity.
The Corporation requires that all employees observe the applicable standards' of
duty and care. An employee may not evade the provisions of the Code by having
another person, including a friend, relative or other, act or fail to act in a
manner in which the employee is prohibited.
I. GENERAL POLICY
It shall be a violation of this Code and its procedures, for any employee of the
firm, in connection with the purchase or sale, directly or indirectly, of any
security held or to be acquired by any client including a registered investment
company or other entity (collectively a "Client"):
1. to employ any device, scheme or artifice to defraud any Client
for which the firm serves as an investment adviser or
sub-adviser;
2. to make to the Client any untrue statement of a material fact
necessary or to omit to state to the Client 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 that
operates or would operate as a fraud or deceit upon the
Client; or
4. to engage in any manipulative practice with respect to the
Client.
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(1) "Employee" shall mean all Monitor employees and Directors.
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II. GUIDELINES AND PROCEDURES
Guidelines
As a fundamental requirement, the Corporation demands the highest
standards of ethical conduct on the part of all its employees. All
employees must abide by this basic standard and never take
inappropriate advantage of their position with the Company.
Each employee is under a duty to exercise his or her authority and
responsibility for the primary benefit of the Corporation and may not
have outside interests conflicting with the interests of the Company.
Each person must avoid any circumstance which might adversely affect or
appear to affect the Corporation, its clients or his or her duty of
complete loyalty to the Corporation in the discharge of his or her
responsibilities. This duty includes the protection of client and
company confidential information and the Corporation's reputation for
trustworthy financial service.
As part of this ongoing responsibility, each employee has the duty to
disclose to the Corporation any interest that he or she may have in any
firm, corporation or business unit which is not affiliated or
participating in any joint venture or partnership with the Corporation
or its affiliates.2 Disclosure should be timely so that Corporation may
take action concerning any possible conflict as it deems appropriate.
It is recognized, however, that the Corporation has or may have
business relationships with many organizations and that a relatively
small interest in publicly traded securities of an organization does
not necessarily give rise to a conflict of interest. Therefore, the
following procedures have been adopted and approved by the Corporation.
Procedures
a) It is considered generally incompatible with an employee's duties to
the Company to assume the position of director of a corporation. A
report should be made by an employee to the Corporation of any
invitation to serve as a director of a corporation which is not an
affiliate and the person must receive the approval of the Chief
Compliance Officer ("CCO") ("" prior to accepting any such
directorship. In the event that approval is given, the corporation in
question shall immediately be placed on Corporation's "Restricted
List".
b) Except as approved by the CCO, it is considered generally incompatible
with the duties of an employee of the Corporation to act as an officer,
general partner, consultant, agent, representative or employee of any
other business, other than an affiliate.
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(2) Affiliates shall mean any corporation controlling, controlled by or under
common control with, the Corporation.
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c) Except as approved by the CCO, employees may not have a monetary
interest, as principal, co-principal, agent or beneficiary, directly or
indirectly, or through any substantial interest in any other
corporation or business unit, in any transaction involving the
Corporation, subject to the same exceptions as are specifically
permitted under law.
d) Once a year, a "Questionnaire On Conflicts Of Interest", shall be
distributed to each employee for completion and filing with the CCO or
his designee. Each employee shall supplement the annual questionnaire
as necessary to reflect any material change between annual filings
e) Gifts/entertainment from third parties that do business with the
Corporation, its affiliates, or its clients and exceed a value of $25
must be reported. You may not accept gifts/entertainment from third
parties with a value exceeding $100 without the prior approval of your
department head.
f) Employees are to disclose to the CCO all personal securities holdings
immediately upon commencement of employment, and in no case later than
ten (10) days beyond the employee's start date. (See the Personal
Investment Policy attached for a copy of the "Employee Initial
Securities Holdings Report and Certification" form).
g) On an annual basis, employees must disclose to the CCO all personal
securities holdings (i.e., all securities that are beneficially owned
by an employee AS OF YEAR-END). The required disclosure should be made
immediately after each calendar year and in no case later than January
30th of any year. (See the Personal Investment Policy attached for a
copy of the "Employee Annual Securities Holdings Report and
Certification" form).
h) All reports furnished pursuant to this policy will be maintained on a
confidential basis and will be reasonably secured to prevent
unauthorized access to such files.
II. THE CODE OF ETHICS AND STANDARDS OF PROFESSIONAL CONDUCT - FOR
FINANCIAL ANALYSTS
All members of the Association for Investment Management and Research
(AIMR) and the holders of and candidates for the Chartered Financial
Analyst designation are also obligated to conduct their activities in
accordance with AIMR Code of Ethics and Standards of Professional
Conduct.
III. MUTUAL FUND CODE OF ETHICS AND SUPPLEMENT THERETO
As discussed above, each employee is under a duty to exercise his or
her authority and responsibility for the primary benefit of the
Company. Employees must abstain from
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participation (or any other involvement) in "insider trading"3 in
contravention of applicable laws or regulations. All personal
securities transactions must be conducted consistent with the Code
(which includes the Corporation's Personal Investment Policy) and in
such a manner as to avoid any actual, potential or apparent conflict of
interest or any abuse of an individual's position of trust and
responsibility. Although the Corporation employees must expressly
comply with the terms of this Code , as an investment adviser to
registered investment companies, the Company and certain of its
employees (i.e., Portfolio Managers, Analysts, Traders etc.) may owe a
specific duty of care to each fund depending upon an employee's status
as an "Access Persons"4 of that mutual fund. The Corporation's
legal/compliance group has reviewed the requirements of Rule 17j-1 of
the Investment Company Act of 1940 and has determined that an
employee's compliance with the company's Code will satisfy not only
that Rules requirements, but the substantive code of ethics
requirements of every registered investment company that we sub-advise.
IV. ACKNOWLEDGMENT
Each employee must certify annually, in substantially the form of
Exhibit A, that he or she has read and understood, and that they are
subject to and have complied with, the Code.
V. SANCTIONS
While compliance with the provisions of the Code is anticipated,
employees should be aware that in response to any violations, the
Company shall take whatever action is deemed necessary under the
circumstances including, but without limitation, the imposition of
appropriate sanctions. These sanctions may include, among others, the
reversal of trades, reallocation of trades to client accounts,
disgorging profits or, in more serious cases, employee suspension or
termination.
------------------
(3) "Insider Trading" is defined as the purchase or sale of securities of a
public company while in possession of material, non-public information or
communicating such information to others.
(4) Rule 17j-1 defines an Access Person as any director, officer, general
partner or "Advisory Person" of the investment advisor who, with respect to any
Fund, makes any recommendation, participates in the determination of which
recommendation will be made, or whose principal function or duties relate to the
determination of which recommendation will be made, or who, in connection with
his or her duties, obtains information concerning recommendations on Covered
securities being made by the investment advisor to any fund. Rule 17j-1 defines
Advisory Person as (i) any employee of the Fund or investment advisor (or of any
company in a control relationship to the Fund or investment advisor) who, in
connection with his or her regular function or duties, makes, participates in,
or obtains information regarding the purchase or sale of Covered securities by a
Fund, or whose functions relate to the making of any recommendations with
respect to the purchase or sales; and (ii) any natural person in a control
relationship to the Fund or investment advisor who obtains information
concerning recommendations made to the Fund with regard to the purchase or sale
of Covered securities by the Fund.
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VI. RECORD-KEEPING
- The Company Compliance Officer and the Local Compliance Officer
must maintain all records relating to compliance with the Code,
such as exception reports, other internal memoranda relating to
non-compliant transactions and preclearance records, for a period
of seven years.
- Upon request by the Company Compliance Officer, a Local Compliance
Officer will provide the Company Compliance Officer access to the
Local Compliance Officer's Code records.
VII. EXCEPTIONS
The Compliance officer, in consultation with internal legal counsel for
the Company and the Local Compliance Officer, if applicable, may grant
written exceptions to provisions of the Code in circumstances which
present special hardship. The exceptions may be granted to individuals
or classes of individuals with respect to particular transactions,
classes of transactions or all transactions. Exceptions shall be
structured to be as narrow as is reasonably practicable with
appropriate safeguards designed to prevent abuse of the exception.
Notwithstanding the foregoing, however, no exception to a provision of
the Code shall be granted where such exception would result in a
violation of Rule 17j-1. Any exception which is granted shall be
reported to the Board at the next regularly scheduled meeting of the
Directors.
VIII. REVIEW BY THE CCO
The CCO will undertake an annual review with respect to the Code to
verify that the Code is being followed. The results of this review will
be set forth in an annual report by the CCO to the Board, not
withstanding any information deemed material in nature, which the CCO
will report at the next scheduled Board meeting. The report shall
specify any related concerns and recommendations and be accompanied by
the appropriate exhibits.
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EXHIBIT A
NYLIFE DISTRIBUTORS, INC. CODE OF ETHICS
ANNUAL CERTIFICATION OF COMPLIANCE WITH THE CODE(S) OF ETHICS
I hereby certify that I have received a copy of NYLIFE Distributors, Inc. Code
of Ethics (the "Code") and have read the Code and understand its requirements. I
further certify that I am subject to the Code and have complied with its all the
requirements set forth there in (other than those that I specifically advised or
have been advised by a representative of Compliance).
-----------------------------
Name:
Position:
--------------------------
Date
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NYLIFE DISTRIBUTORS, INC.
PERSONAL INVESTMENT POLICY
I. IN GENERAL
NYLIFE Distributors, Inc. (the "Corporation" or the "Company") owes an undivided
loyalty to its clients. The Corporation also recognizes the need to permit its
employee's reasonable freedom with respect to their personal investment
activities. It is important to balance in an appropriate way these competing
interests in a way which (a) acknowledges the possibility of conflict between
these duties and (b) sets forth standards to assure that the primary duty of
loyalty to its clients is fulfilled.
This policy ("Policy") supersedes and replaces in full any earlier policies on
the subjects regulated.
The Policy has been implemented by the Corporation although securities purchased
or sold for clients ordinarily trade in a sufficiently broad market to permit
transactions for clients or personal accounts to be completed without any
appreciable impact on the market for such securities.
Any questions which arise relating to the Policy should be referred to the Chief
Compliance Officer ("CCO") or Local Compliance Officer ("LCO"). If necessary,
any final determination of the administration of this policy will be made by the
Chairman or President in consultation with the CCO. This Policy is applicable to
all employees and directors.
II. RECORD KEEPING AND REPORTING REQUIREMENTS
1. Personal Record Keeping
Each employee of the Corporation is to maintain records adequate to establish
that the individual's personal investment decisions did not involve a conflict
with the requirements of the Policy. If there is any question as to whether a
proposed transaction might involve a possible violation of the Policy, the
transaction should be discussed in advance with the CCO or LCO.
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2. Pre-Clearance Reporting Requirement
Each employee shall file with the CCO or LCO (in writing, preferably via
electronic means), a request ("Request") in substantially the form of Exhibit B
before completing any transaction in covered securities in any account over
which the employee exercises "beneficial ownership"1; provided, however, that a
Request need not be filed with respect to any transaction (a) effected in any
account which is managed on a discretionary basis by a person other than such
employee and with respect to which such employee does not in fact influence or
control such transactions and documentation describing that relationship has
been submitted to Compliance or (b) in securities listed in Part III 1 which do
not require prior approval.
3. Other Reporting Requirements
a) Statutory
The Corporation is required under the Investment Advisers Act of 1940 and
Investment Company Act of 1940 to keep records of transactions in
securities in which its directors and employees have direct or indirect
beneficial ownership. The following reporting requirements have been
adopted to enable the Corporation to satisfy these requirements:
1. At the time of hiring, but in no case later than ten (10) days from the
date of commencement of employment with the firm, every new employee shall
submit to the CCO or LCO, a report in substantially the form of Exhibit C
("Employee Initial Securities Holdings Report and Certification"),
disclosing every security and account in which that employee has a direct
or indirect beneficial ownership interests;
2. At the end of each calendar year, but in no case later than January 30th of
the following year, every employee shall submit to the CCO or LCO, a report
in substantially the form of Exhibit D ("Employee Annual Securities
Holdings Report and Certification"), disclosing all personal securities
holdings beneficially owned by an employee AS OF YEAR-END;
3. Each director and employee shall file with the CCO or LCO, a report in
substantially the form of Exhibit E ("Quarterly Report"), within 10 days
following the end of each calendar quarter in which a transaction
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(1) Subject to the specific provisions of Rule 16a-1(a)(2), beneficial ownership
generally means having or sharing, directly or indirectly, through any contract
arrangement, understanding, relationship, or otherwise, a direct or indirect
"pecuniary interest" in the securities. (i) "Pecuniary interest" means the
opportunity, directly or indirectly, to profit or share in any profit derived
from a transaction in the securities. (ii) "Indirect pecuniary interest"
includes: (a) generally, securities held by members of the person's "immediate
family" sharing the same household (which ownership interest may be rebutted);
(b) a general partner's proportionate interest in portfolio securities held by a
general or limited partnership; (c) a person's right to dividends that is
separated or separable from the underlying securities (otherwise, a right to
dividends alone will not constitute a pecuniary interest in securities); (d) a
person's interest in securities held by a trust; (e) a person's right to acquire
securities through the exercise or conversion of any derivative security,
whether or not presently exercisable; and (f) a performance-related fee, other
than an asset based fee, received by any broker, dealer, bank, insurance
company, investment company, investment manager, trustee, or person or entity
performing a similar function, with certain exceptions.
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occurs in Covered securities, other than those listed in Part III (1-4).
The Quarterly Report must be filed for transactions in any security in
which a director or an employee has, or by reason of such transaction
acquires or disposes of, any beneficial ownership. Directors and employees
must also disclose accounts opened or closed since the previous quarter.
Each director and employee must sign and print the date of submission on
their Quarterly Report.
b) Additional Quarterly Reporting
Each employee shall file with the CCO or LCO, as part of the Quarterly
Report, the names and affiliations of family members(2) who are employed in
the securities or commodities industries and who might be in a position to
benefit directly or indirectly from the activities of Monitor's personnel
in the discharge of their duties.
c) Duplicate Confirmations
Each employee shall arrange for prompt filing by the broker, dealer and, if
possible, bank (only applies to bank accounts used substantially as
brokerage accounts) with the CCO or LCO of duplicate confirmations of all
trades of personal securities and quarterly account statements. The
duplicates shall be mailed to NYLIFE Distributors, Inc., 300 Interpace
Parkway, Parsippany, New Jersey 070540, Attention: Compliance Officer.
III. STATEMENT OF RESTRICTIONS
1. Pre-Clearance
To help prevent "front running/scalping"3 and other trading abuses,
particularly with respect to thinly traded securities, no employee of the
Corporation may purchase or sell, directly or indirectly, covered
securities (except pursuant to the next paragraph) without prior approval
of the CCO or LCO. The final determination shall be noted by the CCO or LCO
on the Request Form and dated and communicated to the employee who
submitted the request. The authorization provided by the CCO or LCO is
effective, unless revoked, only for the calendar day that the request was
submitted and ultimately approved. If the covered securities transaction is
not executed on that same day, a new authorization must be obtained.
Subject to the other restrictions set forth in this Part III and other
applicable Corporation's compliance policies relating to personal trading,
transactions in the following instruments only shall not require prior
approval of the CCO or LCO:
------------------
(2) For purposes of this Policy, family members include the individual's spouse,
minor children, parents or any relative of the individual or the individual's
spouse who is sharing the individual's home.
(3) "Front Running" is defined as buying or selling a security prior to the
release of material information. "Scalping" is defined as buying and selling a
security the same day.
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1. Bank Certificates of Deposit
2. Registered Open-End Mutual Fund Shares
3. Treasury Obligations
4. Unit Investment Trusts that hold securities in proportion to a broad
based market index
2. Front Running
No employee of the Corporation may effect any transaction in covered
securities which the Corporation is purchasing or selling for any client or
proposes to purchase or sell for any client if such transaction would in
any way conflict with, or be detrimental to, the interest of the client.
In order to implement the preceding paragraph and to minimize the
possibility of conflicts of interest, the following rules are hereby made
applicable to all transactions by employees in covered securities:
A. No Personal Securities may be purchased or sold if (i) there is a pending
buy or sell order for clients of Corporation(4) or (ii) any purchase or
sale of such securities have been made for the Corporation client accounts
in the prior seven calendar days or can reasonably be anticipated for the
Corporation client accounts in the next seven calendar days.
The CCO or LCO may make an exception to this rule in the event that the
contemplated transaction involves (i) 500 shares or less in the aggregate
and the issuer has market capitalization (outstanding shares multiplied by
the current market price per share) greater than $5 billion; or (ii) 500
shares or less in the aggregate or, less than .001% of the issuer's market
capitalization, if the issuer has market capitalization (outstanding shares
multiplied by the current market price per share) less than $5 billion; or
(iii) investment grade debt instruments less then $100,000.
B. Not withstanding anything expressly stated in the policy, no covered
securities may be purchased or sold if such purchase or sale is effected
with a view to making a profit from a change in the price of such security
resulting from anticipated transactions by or for the Corporation's
clients.
3. Use of Brokerage for Personal or Family Benefit
No employee may, for direct or indirect personal or family members benefit,
execute a trade with a broker by using the influence (implied or stated) of
the Corporation or any director's or employee's influence (implied or
stated) with the Corporation.
4. No Personal Trades Through Corporation's Traders
No Personal Securities trades may be effected through the Corporation's
traders. Employees must effect such trades through their personal
broker-dealers.
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(4) For purposes of this policy, a "pending buy or sell order" shall include
both an order placed with a broker to buy or sell a security at a specified
price or better OR an internal decision by Corporation to buy or sell a security
at a specified price or better.
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5. Initial Public Offerings
No initial public offering of securities may be purchased for any
account in which an employee has beneficial ownership, except with
the express written prior approval by the CCO.
6. Private Placements
No private placement securities may be purchased for any account in
which an employee has beneficial ownership, except with the express
written prior approval by the CCO. All employees who have obtained
prior approval and made an investment in a private placement must
disclose that investment if that employee plays a part in any
subsequent consideration of an investment in the issuer by client
accounts. Under such circumstances, the Corporation's decision to
purchase securities of the private placement issuer will be subject
to an independent review by investment personnel with no investment
in the issuer.
7. Restricted Lists
No employee may make a personal trade in securities of an issuer
listed on the Company's Restricted List. A designated individual from
the Corporation Compliance Department will compare issuers listed on
the Restricted Lists to ensure compliance with this limitation.
8. Inside Information
Employees may not trade on "inside information" (i.e., material and
non-public information) or communicate such information to others.
However, inside information matters must be raised immediately with
the CCO or LCO. Please refer to the New York Life Insurance Company
Policy Statement on Inside Information for specific guidelines
governing inside information.
9. Maximum Trades per Quarter
While there is no maximum limitation on the number of trades that an
employee may execute per quarter, this Code reserves the right of the
CCO or LCO in consultation with the company's President to impose such
a limitation on any employee.
10. Sixty Day Holding Period
No employee may profit from the purchase and sale or sale and purchase
of the same (or equivalent) security within sixty calendar days.
Exceptions may be made for emergency trades if approved by the CCO or
LCO.
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IV. SANCTIONS
Upon discovering a violation of the Policy, the Corporation may impose
sanctions as it deems appropriate, including, among other sanctions,
reversal of any trade, reallocation of trades to client accounts,
disgorgement, or suspension or termination of the employment of the
violator.
V. REVIEW BY CCO
The CCO will undertake an annual review with respect to the Code to
verify that the Code is being followed. The results of this review will
be set forth in an annual report by the CCO to the Board, not
withstanding any information deemed material in nature, which the CCO
will report at the next scheduled Board meeting. The report shall
specify any related concerns and recommendations and be accompanied by
the appropriate exhibits.
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EXHIBIT B
NYLIFE DISTRIBUTORS, INC
REQUEST FOR PRE-CLEARANCE OF PERSONAL SECURITIES TRADING
NAME:
-----------------------------------------
APPROVED / /
--------------------------------
DISAPPROVED / /
--------------------------------
Broker/Account Number
--------------------------
- Trades must be made on the same day that approval is received.
<TABLE>
<CAPTION>
# OF SHRS, SEC. PURCHASE (P) DIRECT OWNERSHIP (D)
PRINCIPAL AMOUNT, SYMBOL OR MKT. SALE SPOUSE (S)
DATE NAME OF SECURITY ETC. APPROX PRICE CUSIP # CAP. (S) CONTROL (C)
---- ---------------- ---- ------------ ------- ---- --- -----------
<S> <C> <C> <C> <C> <C> <C> <C>
</TABLE>
THE PERSON INDICATED ABOVE HAS STATED AND REPRESENTS THAT:
(a) he/she has no insider information (specifically information relating to
planned securities transactions by Monitor) relating to the above
referenced issuer(s);
(b) there is no conflict of interest in these transactions with respect to
client portfolios (IF A CONFLICT OF INTEREST EXIST, PLEASE CONTACT
COMPLIANCE DEPARTMENT IMMEDIATELY.); and
(c) these securities are not initial public offerings nor private placements.
<PAGE> 14
EXHIBIT C
EMPLOYEE INITIAL SECURITIES HOLDINGS REPORT AND CERTIFICATION
Statement to NYLIFE Distributors, Inc By
---------------------------------
(Please print your full name)
Today's Date:
----------------
As of the date appearing above, the following are each and every security
and account in which I have a direct or indirect "Beneficial Ownership"
Interest (not including bank certificates of deposit, open-end mutual fund
shares Treasury obligations and Unit Investment Trusts that hold securities
in proportion to a broad base index). For purposes of this report, the term
Beneficial Ownership shall mean, ownership of securities or securities
accounts by or for the benefit of a person, or such person's "family
member", including any account in which the employee, or family member of
that person holds a direct or indirect beneficial interest, retains
discretionary investment authority or exercises a power of attorney. The
term "family member" means any person's spouse, child or other relative,
whether related by blood, marriage or otherwise, who either resides with,
or is financially dependent upon, or whose investments are controlled by
that person and any unrelated individual whose investments are controlled
and whose financial support is materially contributed to by the person,
such as a "significant other."
<TABLE>
<CAPTION>
AMOUNT (NO. OF NATURE OF INTEREST BROKER, DEALER (OR
SHARES OR (DIRECT OWNERSHIP, BANK ACTING AS
NAME OF SECURITY SECURITY TYPE PRINCIPAL AMOUNT) SPOUSE, CONTROL, ETC.) BROKER) INVOLVED
---------------- ------------- ----------------- ---------------------- ----------------
<S> <C> <C> <C> <C>
</TABLE>
I CERTIFY THAT THE SECURITIES LISTED ABOVE, ARE THE ONLY SECURITIES IN WHICH I
HAVE A DIRECT OR INDIRECT BENEFICIAL OWNERSHIP INTEREST.
EMPLOYEE SIGNATURE:
----------------------------------
<PAGE> 15
<TABLE>
<S> <C> <C>
Received By: _____________________ Reviewed By: ___________________ COMMENTS:
Title:____________________________ Title:___________________________
Date: ___________________ Date:______________________
</TABLE>
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EXHIBIT D
EMPLOYEE ANNUAL SECURITIES HOLDINGS REPORT AND CERTIFICATION
Statement to NYLIFE Distributors, Inc. By
----------------------------------
(Please print your full name)
For the Calendar year ended
----------------
I certify that the following are all Personal Securities holdings (not including
bank certificates of deposit, registered open-end mutual fund shares, Treasury
obligations (i.e., TBills, Notes and Bonds) and Unit Investment Trusts that hold
securities in proportion to a broad base index) beneficially held by me as of
the year end appearing above.* By "Personal Securities" I mean any securities
over which I have influence or control and also any securities (i) in which I,
my spouse, or members of our family (including my parents, minor children and
any relative of mine who is sharing my home) have beneficial ownership or (ii)
from which I or they derive in any manner benefits substantially equivalent to
those of ownership.
<TABLE>
<CAPTION>
Amount (No. of Nature of Interest Broker, Dealer (or
Name of Shares or Purchase (Direct Ownership, Bank acting as
Security Principal Amount) Date Security Type Price Spouse, Control, Etc.) Broker) Involved
-------- ----------------- ---- ------------- ----- ---------------------- ----------------
<S> <C> <C> <C> <C> <C> <C>
</TABLE>
Signature: Date:
--------------------------------- ---------------------
Received By: Reviewed By: Comments:
---------------- -----------------
Title: Title:
---------------- -----------------
Date: Date:
---------------- -----------------
<PAGE> 17
*NOTE: IN LIEU OF AN EMPLOYEE LISTING ON THIS FORM EACH SECURITY HELD AS OF
YEAR-END, HE/SHE MAY ATTACH AS AN EXHIBIT TO THIS DOCUMENT, AND ANNUAL
STATEMENT(S) FROM EVERY BROKERAGE FIRM WITH WHICH AN EMPLOYEE HAS A BENEFICIAL
SECURITY INTEREST. NOTWITHSTANDING THIS ACCOMMODATION, IT IS THE EMPLOYEE'S SOLE
RESPONSIBILITY TO ENSURE THAT THE INFORMATION REFLECTED IN THAT STATEMENT(S) IS
ACCURATE AND COMPLETELY DISCLOSES ALL RELEVANT SECURITIES HOLDINGS.
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EXHIBIT E
QUARTERLY REPORT OF SECURITIES TRANSACTIONS
Statement to NYLIFE Distributors, Inc. By
---------------------------------
(Please print your full name)
For the Calendar quarter ended
--------------
The following are all transactions in Personal Securities (not including bank
certificates of deposit, registered open-end mutual fund shares, Treasury
obligations (i.e., TBills, Notes and Bonds) and Unit Investment Trusts that hold
securities in proportion to a broad base index) effected during the quarter. By
"Personal Securities" I mean any securities over which I have influence or
control and also any securities (i) in which I, my spouse, or members of our
family (including my parents, minor children and any relative of mine who is
sharing my home) have beneficial ownership or (ii) from which I or they derive
in any manner benefits substantially equivalent to those of ownership.
<TABLE>
<CAPTION>
Amount (No. of Nature of Interest Broker, Dealer (or
Name of Shares or Trade Nature of Transaction, (Direct Ownership, Bank acting as
Security Principal Amount) Date (Purchase, Sale, Etc.) Price Spouse, Control, Etc.) Broker) Involved
-------- ----------------- ---- ---------------------- ----- ---------------------- ----------------
<S> <C> <C> <C> <C> <C> <C>
</TABLE>
Since the prior Quarterly Report, I have opened or closed the following accounts
(including brokerage accounts and bank accounts used substantially as brokerage
accounts):
<TABLE>
<CAPTION>
Firms Through Which Date Account
Account Name and Number Transactions Are Effected Opened or Closed
----------------------- ------------------------- ----------------
<S> <C> <C>
</TABLE>
In connection with any purchases or sales of securities for clients during the
quarter, I disclosed to NYLIFE Distributors, Inc. any material interests in my
Personal Securities which might reasonably have been expected to involve a
conflict with the interests of clients. Also, I have disclosed all my Personal
Securities holdings to NYLIFE Distributors, Inc..
The names and affiliations of family members (see above) who are employed in the
securities or commodities industries and who might be in a position to benefit
directly or indirectly from the activities of the NYLIFE Distributor, Inc.
personnel in the discharge of their duties are as follows:
<TABLE>
<CAPTION>
Names Affiliations
----- ------------
<S> <C>
</TABLE>
<PAGE> 19
Date: Signature:
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