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NEW YORK LIFE INVESTMENT MANAGEMENT LLC
CODE OF ETHICS
This Code of Ethics (the "Code") has been issued by New York Life Investment
Management LLC ("NYLIM" 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
NYLIM 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.
NYLIM 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 NYLIM employees and directors.
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II. GUIDELINES AND PROCEDURES
Guidelines
As a fundamental requirement, NYLIM 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 NYLIM 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
NYLIM, its clients or his or her duty of complete loyalty to NYLIM in the
discharge of his or her responsibilities. This duty includes the
protection of client and company confidential information and NYLIM's
reputation for trustworthy financial service.
As part of this ongoing responsibility, each employee has the duty to
disclose to NYLIM 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 NYLIM or its affiliates.(2)
Disclosure should be timely so that NYLIM may take action concerning any
possible conflict as it deems appropriate. It is recognized, however, that
NYLIM 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
NYLIM.
Procedures
a) It is considered generally incompatible with an employee's duties to NYLIM
to assume the position of director of a corporation. A report should be
made by an employee to NYLIM 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 NYLIM's "Restricted List".
b) Except as approved by the CCO, it is considered generally incompatible
with the duties of an employee of NYLIM to act as an officer, general
partner, consultant, agent, representative or employee of any other
business, other than an affiliate.
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 NYLIM, subject to the same exceptions
as are specifically permitted under law.
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(2) Affiliates shall mean any corporation controlling, controlled by or under
common control with, NYLIM.
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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 NYLIM, 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 Exhibit C of 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 Exhibit D of 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 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 NYLIM'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 NYLIM 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
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(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.
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status as an "Access Persons"(4) of that mutual fund. NYLIM'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.
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
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(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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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
NEW YORK LIFE INVESTMENT MANAGEMENT LLC CODE OF ETHICS
ANNUAL CERTIFICATION OF COMPLIANCE WITH THE CODE(S) OF ETHICS
-
I hereby certify that I have received a copy of New York Life Investment
Management LLC 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).
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Name:
Position:
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Date
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NEW YORK LIFE INVESTMENT MANAGEMENT LLC
PERSONAL INVESTMENT POLICY
I. IN GENERAL
New York Life Investment Management LLC ("NYLIM") owes an undivided
loyalty to its clients. NYLIM 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 NYLIM 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 NYLIM 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.
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
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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
NYLIM 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 NYLIM 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 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 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. Employees must also
disclose accounts opened or closed since the previous quarter. Each
employee must sign and print the date of submission on their Quarterly
Report.
(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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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 Madison Square
Advisors LLC, 51 Madison Ave., New York, New York 10010, 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
NYLIM 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 NYLIM's compliance policies relating to personal trading,
transactions in the following instruments only shall not require prior
approval of the CCO or LCO:
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
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(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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No employee of NYLIM may effect any transaction in covered securities
which NYLIM 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 NYLIM(4) or (ii) any
purchase or sale of such securities have been made for NYLIM client
accounts in the prior seven calendar days or can reasonably be
anticipated for NYLIM 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
NYLIM'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 NYLIM or any director's or employee's influence (implied
or stated) with NYLIM.
4. No Personal Trades Through NYLIM's Traders
No Personal Securities trades may be effected through NYLIM's traders.
Employees must effect such trades through their personal broker-dealers.
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
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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 NYLIM to buy or sell a security
at a specified price or better.
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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, NYLIM'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 NYLIM
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.
IV. SANCTIONS
Upon discovering a violation of the Policy, NYLIM 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
NEW YORK LIFE INVESTMENT MANAGEMENT LLC
REQUEST FOR PRE-CLEARANCE OF PERSONAL SECURITIES TRADING
NAME:
----------------------------------------------------------------
APPROVED / /
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DISAPPROVED / /
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Broker/Account Number
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- Trades must be made on the same day that approval is received.
<TABLE>
<CAPTION>
------------------------------------------------------------------------------------------------
# OF SHRS, SYMBOL OR SEC. PURCHASE (P) DIRECT OWNERSHIP
DATE NAME OF PRINCIPAL APPROX CUSIP # MKT. SALE (D)
SECURITY AMOUNT, ETC. PRICE CAP. (S) SPOUSE (S)
CONTROL (C)
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<S> <C> <C> <C> <C> <C> <C> <C>
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------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------------
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</TABLE>
THE PERSON INDICATED ABOVE HAS STATED AND REPRESENTS THAT:
<PAGE> 13
(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.
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EXHIBIT C
EMPLOYEE INITIAL SECURITIES HOLDINGS REPORT AND CERTIFICATION
Statement to New York Life Investment Management LLC 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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EMPLOYEE ANNUAL SECURITIES HOLDINGS REPORT AND CERTIFICATION
Statement to New York Life Investment Management LLC 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:
-----------------------------
<TABLE>
<S> <C> <C>
Received By: Reviewed By: COMMENTS:
------------------------- ----------------------------
Title: Title:
------------------------- ----------------------------
Date: Date:
------------------------- ----------------------------
</TABLE>
<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 New York Life Investment Management LLC 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 New York Life Investment Management LLC 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 New York Life Investment Management LLC.
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 NYLIM personnel in the discharge
of their duties are as follows:
<TABLE>
<CAPTION>
Names Affiliations
----- ------------
<S> <C>
</TABLE>
Date:
--------------------------------
Signature:
--------------------------------
