<PAGE>
The Tuscarora Investment Trust
Code of Ethics
August 28, 2000
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The Tuscarora Investment Trust (the "Fund") is confident that its trustees and
officers act with integrity and good faith. The Fund recognizes, however, that
personal interests may conflict with the interests of shareholders. In an effort
to prevent any conflicts of interest and in accordance with Rule 17j-1 under the
Investment Company Act of 1940, as amended (the "1940 Act"), the Fund has
adopted this Code of Ethics (the "Code") to address transactions that may create
conflicts of interest, and to establish reporting requirements and enforcement
procedures.
This Code is based on the principle that the trustees and officers of the Fund
have a fiduciary duty to place the interests of shareholders first and to
conduct all personal securities transactions in a manner that does not interfere
with Fund transactions or otherwise take unfair advantage of the relationship of
the trustees and officers to the Fund. Fund personnel must adhere to this
general principle as well as comply with the specific provisions of this Code.
Technical compliance with this Code will not insulate from scrutiny trades which
indicate an abuse of an individual's fiduciary duty.
A. STATEMENT OF GENERAL PRINCIPLES
In recognition of the trust and confidence placed in the Fund by its
shareholders, and to give effect to the belief that the Fund's operations should
be directed to the benefit of its shareholders, the Fund hereby adopts the
following general principles to guide the actions of its trustees and officers:
(1) The interests of the Fund and its shareholders are paramount.
In conducting themselves and the operations of the Fund, all
Fund personnel must place the interests of the shareholders
before their own.
(2) The personal securities transactions of Fund personnel must be
effected in such a way as to avoid a conflict between the
personal interests of Fund personnel and the interests of the
Fund's shareholders.
(3) Fund personnel must avoid actions or activities that allow
such a person, or a member of his or her family to profit or
benefit from his or her position with the Fund, or that
otherwise call into question such person's independent
judgement.
B. DEFINITIONS
(1) "ACCESS PERSON" means:
- any trustee or officer of the Fund;
- any employee of the Fund (or of any company in a
control relationship to the Fund) who, in connection
with his or her regular functions or duties, makes,
participates in, or obtains information regarding
the purchase or sale of a Covered Security for the
Fund, or whose functions relate to the making of any
recommendations with respect to such purchases or
sales; and
- any natural person in a control relationship to the
Fund who obtains information concerning
recommendations made to the Fund with regard to the
purchase or sale of a Covered Security for the Fund.
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(2) "ALTERNATE REVIEW OFFICER" is any person appointed by the Fund
to review the reports of the Compliance Officer or to perform
such other duties as may be required to assist the Compliance
Officer in fulfilling his or her obligations under this Code.
(3) "BENEFICIAL OWNERSHIP" of a security is to be interpreted in
the same manner as it is for purposes of Section 16 of the
Securities Exchange Act of 1934 and Rule 16a-1(a)(2)
thereunder. This means that a person will generally be
considered to have "beneficial ownership" of any security in
which he or she has direct or indirect pecuniary (monetary)
interest. In addition, a person will be deemed to have
"beneficial ownership" of securities held by his or her
spouse, minor children, a relative who shares the same home,
or other persons by reason of any contract, arrangement,
understanding or relationship that provides him or her with
sole or shared investment power.
(4) "COMPLIANCE OFFICER" means the person(s) appointed by the Fund
to administer the provisions of this Code. Where this Code
requires action by the Compliance Officer, the Compliance
Officer will consult with such management personnel of the
Fund as may be appropriate under the circumstances.
(5) "CONTROL" has the same meaning as that set forth in Section
2(a)(9) of the 1940 Act. Section 2(a)(9) of the 1940 Act
provides that "control" means the power to exercise a
controlling influence over the management or policies of a
company, unless such power is solely the result of an official
position with such company. Ownership of 25% or more of a
company's outstanding voting securities is presumed to give
the holder thereof control over the company; however, this
presumption may be countered by the facts and circumstances of
a given situation.
(6) "COVERED SECURITY" has the same meaning as that set forth in
Section 2(a)(36) of the 1940 Act, and includes stocks, bonds,
investment contracts, profit-sharing agreements, transferable
shares, options on securities, limited partnership interests,
or in general any interest or instrument commonly known as a
"security." However, in the case of an interest in a limited
partnership that invests in securities, the Covered Security
will be the interest in the limited partnership, and not the
underlying securities in which the partnership invests,
provided that the partnership receives investment advice based
on its investment objectives rather than on the individual
investment objectives of its limited partners.
Covered Security does not include:
direct obligations of the Government of the United States;
- bankers' acceptances, bank certificates of deposit,
commercial paper and high quality short-term debt
instruments, including repurchase agreements;
- shares issued by registered open-end investment
companies; and
- any instrument that is not a security as defined in
Section 2(a)(36) of the 1940 Act. These instruments
include, but are not limited to:
- futures contracts;
- options on a futures contracts;
- general partnership interests, provided
generally that the general partnership
interest entitles the owner to exercise
management control over the partnership;
and
- direct interests in real estate.
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(7) "INDEPENDENT TRUSTEE" means a trustee of the Fund who is not
an "interested person" of the Fund within the meaning of
Section 2(a)(19) of the 1940 Act.
(8) "INITIAL PUBLIC OFFERING" means an offering of securities
registered under the Securities Act of 1933, the issuer of
which, immediately before the registration, was not subject to
the reporting requirements of Sections 13 or 15(d) of the
Securities Exchange Act of 1934.
(9) "LIMITED OFFERING" means an offering that is exempt from
registration under the Securities Act of 1933 pursuant to
Section 4(2), Section 4(6), Rule 504, Rule 505 or Rule 506
(I.E., a private placement).
(10) "PURCHASE OR SALE OF A COVERED SECURITY" includes, among other
things, the writing of an option to purchase or sell a Covered
Security and any securities convertible into a Covered
Security.
(11) A Covered Security "HELD OR TO BE ACQUIRED" means (i) any
Covered Security which, within the most recent fifteen days
(A) is or has been held by the Fund, or (B) is being or has
been considered for purchase by the Fund; and (ii) any option
to purchase or sell, any security convertible into or
exchangeable for, any such Covered Security.
(12) A Covered Security is "BEING PURCHASED OR SOLD" by the Fund
from the time when a purchase or sale decision has been made
or a purchase or sale program has been transmitted to the
person who places buy and sell orders for the Fund until the
time when such program has been fully completed or terminated.
C. RESTRICTIONS ON PERSONAL SECURITIES TRANSACTIONS
(1) PROHIBITION AGAINST FRAUD, DECEIT AND MANIPULATION. No Access
Person will, in connection with the purchase or sale, directly
or indirectly, by such person of a Covered Security held or to
be acquired by the Fund:
- employ any device, scheme or artifice to defraud the
Fund;
- make any untrue statement of a material fact to the
Fund or omit to state a material fact necessary in
order to make the statements made to the Fund, in
light of the circumstances under which they are
made, not misleading;
- engage in any act, practice or course of business
which would operate as fraud or deceit on the Fund;
or
- engage in any manipulative practice with respect to
the Fund.
(2) PRE-CLEARANCE REQUIRED. Unless specifically excepted under
this Code, no Access Person may purchase or sell, directly or
indirectly, any Covered Security in which such Access Person
has (or by reason of such transaction acquires) any Beneficial
Ownership without obtaining prior approval from the Compliance
Officer in the manner prescribed by the Compliance Officer.
This pre-clearance requirement also applies to Covered
Securities proposed to be acquired by an Access Person in a
Limited Offering.
(3) PROHIBITION ON INITIAL PUBLIC OFFERINGS. No Access Person may
directly or indirectly acquire beneficial ownership of any
Covered Security in an Initial Public Offering.
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(4) BLACKOUT PERIOD ON PERSONAL SECURITIES TRANSACTIONS. Except as
specifically permitted by this Code, no Access Person may
purchase or sell, directly or indirectly, any Covered Security
in which such Access Person has (or by reason of such
transaction acquires) any Beneficial Ownership on the same day
that the same (or a related) Covered Security is being
purchased or sold for the Fund.
(5) LIMITS ON PERSONAL GIFTS. No Access Person will accept from
any person or entity (including shareholders and vendors) that
does business with or on behalf of the Fund ("Business
Associate") a personal gift of more than DE MINIMIS value
without the prior approval of the Compliance Officer. For
purposes of this paragraph, "DE MINIMIS" means a fair market
value of $250 or less. The solicitation or giving of personal
gifts by Access Persons is also prohibited without prior
approval. The Compliance Officer may exempt individuals or
groups of individuals from the restrictions of this paragraph
where the risk of abuse is minimal or non-existent.
In addition, these restrictions do not apply to:
- Usual and customary promotional items given to or
received from Business Associates (E.G., hats, pens,
T-shirts, mugs, and similar items marked with
logos);
- Normal and customary business meals and
entertainment with Business Associates. For example,
if an Access Person has a business meal or attends a
sporting event or show with a Business Associate,
that activity would not be subject to the
restrictions of this paragraph, provided the
Business Associate is present. If, on the other
hand, the Business Associate provides tickets to a
sporting event and the Access Person attends the
event without the Business Associate also being
present, the tickets would be subject to the dollar
limit set forth above; and
- Gifts based on family and personal relationships.
(5) LIMITS ON DIRECTORSHIPS OF PUBLICLY TRADED COMPANIES. No
Access Person may serve on the board of directors of a
publicly traded company, absent prior written authorization
from the Compliance Officer. The Compliance Officer will grant
authorization only if the Compliance Officer determines in his
or her reasonable judgement based on the facts known at the
time and, if necessary, consultation with appropriate
management personnel of the Fund, that board service would not
be inconsistent with the interests of the Fund and its
shareholders. In the event board service is authorized, such
individuals serving as directors will be isolated from those
making investment decisions regarding the publicly traded
company through procedures designed to safeguard against
potential conflicts of interest, such as Chinese Wall policies
or investment restrictions.
(6) PERSONAL BENEFIT. No Access Person will cause or attempt to
cause the Fund to purchase, sell or hold any Covered
Security in a manner calculated to create any personal
benefit to such Access Person or a member of his or her
family. If an Access Person or a member of his or her family
stands to materially benefit from an investment decision for
the Fund that the Access Person is recommending or in which
the Access Person is participating, the Access Person will
disclose to the Compliance Officer and persons with
authority to make investment decisions for the Fund, any
beneficial interest that the Access Person or a member of
his or her family has in such Covered Security (or a related
security), or the issuer thereof, where the decision could
create a material benefit to the Access Person or a member
of his or her family or the appearance of impropriety.
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D. EXEMPTIONS FROM PRE-CLEARANCE
(1) INDEPENDENT TRUSTEES. The pre-clearance requirements of this
Code shall not apply to purchases and sales by Independent
Trustees.
(2) EXEMPT TRANSACTIONS. Transactions in the following Covered
Securities are not subject to pre-clearance:
(a) DRIPS. Purchases of equity securities held in
dividend reinvestment plans ("DRIPs").
(b) RIGHTS OFFERINGS. Purchases effected on the
exercise of rights issued by an issuer PRO RATA to
all holders of a class of its securities, to the
extent such rights were acquired from such issuer,
and sales of such rights so acquired.
(c) BROAD-BASED INDEX OPTIONS. Purchases or sales of
index options or other securities that derive their
value from indices designated by the Compliance
Officer as broad-based.
(d) OTHER. Purchases or sales of other securities as may
from time to time be designated in writing by the
Compliance Officer on the grounds that the risk of
abuse is minimal or non-existent.
E. APPLICATION OF PRE-CLEARANCE REQUIREMENT
(1) DE MINIMIS TRANSACTIONS. The Compliance Officer will generally
grant clearance for the purchase or sale of any Covered
Security by an Access Person if such purchase or sale
qualifies as "DE MINIMIS" under this paragraph; provided,
however, that clearance requests will not be granted for
transactions in Covered Securities that are being considered
for purchase or sale for the Fund, even if the transaction
would qualify as DE MINIMIS under this paragraph.
In determining whether a particular transaction is DE MINIMIS
under this paragraph, the Compliance Officer will consult with
investment management personnel and/or counsel, as
appropriate. For this purpose, a transaction will be deemed
"DE MINIMIS" if it satisfies any of the following standards:
- NUMBER OF SHARES. Any transaction in an actively
traded Covered Security for 1,000 shares or less. In
the case of a less liquid Covered Security, the
Compliance Officer will use a share amount threshold
that is appropriate in light of the trading
characteristics of the Covered Security and the
potential for harm to the interests of the Fund and
its shareholders;
- DOLLAR VALUE OF TRANSACTION. Any transaction in an
actively traded Covered Security with a dollar value
of $25,000 or less. In the case of a less liquid
security, the Compliance Officer will use a dollar
amount threshold that is appropriate in light of the
trading characteristics of the Covered Security and
the potential for harm to the interests of the Fund
and its shareholders; or
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- RECENT TRADING VOLUME. Any transaction in a Covered
Security that is less than 2% of the average daily
trading volume for the past 10 weeks.
(2) BLACKOUT PERIOD. Unless they qualify under paragraphs 1 of
this section, the Compliance Officer will not grant clearance
for securities transactions involving Covered Securities that
are prohibited under the blackout period described in
paragraph 4 of section C because the Covered Security (or a
related security) is being purchased or sold by the Fund on
the same day. Such "related securities" include options and
convertible securities. Thus, in the case of options,
clearance will not be granted if the underlying security is
being purchased or sold, or considered for purchase or sale by
the Fund. Similarly, clearance will not be granted for
convertible securities if either the convertible securities
themselves or the securities into which they are convertible
are being purchased or sold by the Fund.
(3) SPECIAL CONSIDERATIONS FOR LIMITED OFFERINGS. In determining
whether to approve a request for the purchase or sale of
securities in a Limited Offering, the Compliance Officer will
consider, among other things, the following:
- POSSIBILITY OF FUTURE IMPACT ON THE FUND. The
Compliance Officer will consider whether there is
any reasonable likelihood that the company making
the Limited Offering, or any companies it owns or
controls, might in the foreseeable future make an
Initial Public Offering of securities that might be
appropriate investments for the Fund. Among other
things, the Compliance Officer will, as appropriate,
consult with persons with the authority to make
investment decisions for the Fund to determine
whether, based on a reasonable judgement and the
facts known at the time of the pre-clearance
request, such securities would reasonably be
expected to be appropriate investments for the Fund.
- SIZE OF INVESTMENT. The Compliance Officer will
consider the size of the potential investment (I.E.,
the percent of outstanding securities of the issuing
entity of which the Access Person will be deemed to
have Beneficial Ownership).
(4) DISCRETION OF COMPLIANCE OFFICER. Notwithstanding the
provisions of paragraph 1 of this section, the Compliance
Officer may refuse to grant clearance for any transaction if
he or she deems the transaction to involve a conflict of
interest, possible diversion of a corporate opportunity, or
any appearance of impropriety.
(5) PRE-CLEARANCE OF THE COMPLIANCE OFFICER'S PERSONAL SECURITIES
TRANSACTIONS. The Compliance Officer will clear his or her own
personal securities transactions in advance through the
Alternate Review Officer who will fulfill the duties of the
Compliance Officer with regard to the Compliance Officer's
pre-clearance requests.
(6) EFFECTIVENESS OF PRE-CLEARANCE. Clearance is effective, unless
earlier revoked, until the earlier of: (i) the close of
business on the trading day such clearance was granted, or
(ii) the time the Access Person learns that the information
provided to the Compliance Officer in such Access Person's
request for clearance is not accurate. Clearance may be
revoked at any time by the Compliance Officer or the Alternate
Review Officer. Clearance requests will not be granted for
transactions in Covered Securities that are being considered
for purchase or sale for the Fund. This paragraph relates to
all transactions, regardless of whether they would qualify as
DE MINIMIS.
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F. REPORTING OBLIGATIONS
(1) INITIAL HOLDINGS REPORT. Each Access Person must submit a list
of all Covered Securities for which such Access Person had any
direct or indirect Beneficial Ownership, as well as a list of
any broker, dealer or bank account in which any securities are
held for the direct or indirect benefit of the Access Person,
as of the date such Access Person first becomes subject to
this Code's reporting requirements. The Initial Holdings
Report must be submitted to the Compliance Officer within 10
days of the date the Access Person becomes subject to this
Code's reporting requirements. An Initial Holdings Report Form
is attached as EXHIBIT A. INDEPENDENT TRUSTEES ARE NOT
REQUIRED TO SUBMIT AN INITIAL HOLDINGS REPORT PURSUANT TO THIS
PARAGRAPH.
(2) ANNUAL HOLDINGS REPORT. On an annual basis, each Access Person
must submit to the Compliance Officer a list of all Covered
Securities for which such Access Person has any direct or
indirect Beneficial Ownership, as well as a list of any
broker, dealer or bank account in which any securities are
held for the direct or indirect benefit of the Access Person.
The list of Covered Securities and accounts contained in the
Annual Holdings Report must be current as of a date no more
than 30 days before the submission of the Annual Holdings
Report. An Annual Holdings Report Form is attached as EXHIBIT
B. INDEPENDENT TRUSTEES ARE NOT REQUIRED TO SUBMIT ANNUAL
HOLDINGS REPORTS PURSUANT TO THIS PARAGRAPH.
(3) QUARTERLY TRANSACTION REPORTS.
(a) On a quarterly basis, each Access Person must report
any transaction during a quarter in a Covered
Security in which such Access Person has (or by
virtue of the transaction acquires) any direct or
indirect Beneficial Ownership, as well as any
broker, dealer or bank account established during
the quarter in which securities are held for the
direct or indirect benefit of the Access Person.
Each Access Person must submit the Quarterly
Transaction Report to the Review Officer NO LATER
THAN 10 days after the end of each calendar quarter.
A Quarterly Transaction Report Form is included as
EXHIBIT C.
(b) In the event that no reportable transactions
occurred during the quarter and no securities
accounts were opened, the Access Person is still
required to submit a Quarterly Transaction Report.
The Access Person should note on the report that
there were no reportable items during the quarter,
and return it, signed and dated.
(c) An Access Person is not required to list security
transactions on a Quarterly Transaction Report if
the report would duplicate information contained in
broker trade confirmations or periodic account
statements received by the Compliance Officer. In
order to rely on this reporting mechanism, the
Access Person must arrange for: (i) the Compliance
Officer to receive duplicate copies of trade
confirmations and periodic account statements
directly from the broker-dealer; and (ii) a copy of
the relevant periodic account statement to be
attached to the Quarterly Transaction Report. The
trade confirmations and periodic account statements
must contain all required information and the
Quarterly Transaction Report and the accompanying
documentation must be received by the Compliance
Officer NO LATER THAN 10 days after the end of the
calendar quarter.
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(d) Independent Trustees shall report personal
securities transactions only if the Independent
Trustee knew at the time of the time of the
transaction or, in the ordinary course of fulfilling
his or her official duties as a trustee, should have
known, that during the 15 day period immediately
preceding or following the date of the Independent
Trustee's transaction, the Covered Security was
purchased or sold, or was being considered for
purchase or sale, by the Fund.
The "should have known" standard does not:
- imply a duty of inquiry;
- presume that an Independent Trustee should
have deduced or extrapolated information
about the purchases and sales of the Fund
from discussions or memoranda dealing with
the Fund's investment strategies; or
- impute knowledge from an Independent
Trustee's awareness of the Fund's
portfolio holdings, market considerations,
or investment policies, objectives and
restrictions.
(4) EXEMPTIONS FROM REPORTING. Access Persons are not subject to
the reporting requirements in (1), (2), and (3) above for
purchases or sales effected for any account over which the
Access Person does not have any direct or indirect influence
or control.
(5) ALTERNATE REVIEW OFFICER. The Compliance Officer will submit
his or her own reports required by this section to the
Alternate Review Officer who will fulfill the duties of the
Compliance Officer with regard to the Compliance Officer's own
reports.
(6) DISCLAIMER OF BENEFICIAL OWNERSHIP. Any report required by
this section may contain a statement that the report will not
be construed as an admission by the person making such report
that he or she has any direct or indirect Beneficial Ownership
in the Covered Security to which the report relates.
G. REVIEW AND ENFORCEMENT
(1) The Compliance Officer will notify each person who becomes an
Access Person of the Fund and who is required to report under
this Code of their reporting requirements NO LATER THAN 10
days before the first quarter in which such person is required
to begin reporting.
(2) The Compliance Officer will, on a quarterly basis, compare all
reported personal securities transactions with completed
transactions of the Fund during the period to determine
whether a violation of this Code may have occurred. In
determining whether a violation occurred, the Compliance
Officer will consult with appropriate management personnel of
the Fund and they will consider the facts and circumstances
surrounding the occurrence along with the explanation and
discussion thereof by interested and/or involved parties and
their supervisors.
(3) If a violation is found to have occurred, the Compliance
Officer and appropriate management personnel of the Adviser
will impose, after consultation with outside counsel (as
appropriate), such corrective action as they deem appropriate
under the circumstances.
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H. RESPONSIBILITIES TO THE BOARD OF TRUSTEES OF THE FUND
(1) ANNUAL WRITTEN REPORT. At least annually, the Fund and the
Adviser will provide to the Board of Trustees, and the Board
of Trustees will consider, a written report that:
(a) Describes any issues arising under the relevant code
of ethics that arose during the prior year (or since
the last report to the Board of Trustees),
including, but not limited to, information about
material violations of the codes and any resulting
sanctions; and
(b) Certifies that the Fund or the Adviser, as
applicable, has adopted procedures reasonably
necessary to prevent their access persons from
violating their respective codes of ethics.
(2) MATERIAL AMENDMENTS TO THE CODE. The Fund and the Adviser will
promptly report to the Board of Trustees in writing any
material amendment to their respective codes of ethics.
I. INTERRELATIONSHIP WITH OTHER CODES OF ETHICS
(1) SINGLE REPORTING OBLIGATION. A person who is both an Access
Person of the Fund and an access person of the Adviser or
BISYS Fund Services, Inc. (the "Administrator") is only
required to report under and otherwise comply with the code of
ethics of the Adviser or the Administrator, as applicable;
provided, however, that such code has been adopted pursuant to
and in compliance with Rule 17j-1.
(2) PROCEDURES. The Adviser and Administrator will each promptly
furnish to the Fund, upon request, copies of any reports made
under its code of ethics by any person who is also covered by
the Fund's Code.
J. RECORDS
The Fund will maintain records in the manner and to the extent set forth below.
Such records will be available for examination by representatives of the
Securities and Exchange Commission.
(1) A copy of this Code and any other code of ethics adopted by
the Fund that is, or at any time within the past five years
has been, in effect (maintained in an easily accessible
place).
(2) A record of any violation of this Code and of any action taken
or sanction imposed as a result of any such violation
(maintained in an easily accessible place for a period of at
least five years following the end of the fiscal year in which
the violation occurs).
(3) A copy of each report submitted under this Code, including any
information provided in lieu of any such reports made under
the Code (maintained for a period of at least five years from
the end of the fiscal year in which it is made, the first two
years in an easily accessible place).
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(4) A record of all persons, currently or within the past five
years, who are or were required to submit reports under this
Code, and those persons who are or were responsible for
reviewing the reports (maintained in an easily accessible
place).
(5) A copy of each annual report required by paragraph 1 of
section H of this Code (maintained for at least five years
from the end of the fiscal year in which such annual report is
made, the first two years in an easily accessible place).
(6) A record of any decision, and the reasons supporting the
decision, to approve the acquisition of securities acquired in
a Limited Offering (maintained for at least five years after
the end of the fiscal year in which the approval is granted).
K. MISCELLANEOUS
(1) CONFIDENTIALITY. All reports of securities transactions and
any other information filed with the Fund pursuant to this
Code will be treated as confidential; provided, however, that
copies of such reports and information may be disclosed to the
Securities and Exchange Commission or as may otherwise be
required to comply with applicable law.
(2) INTERPRETATION OF PROVISIONS. The Fund may from time to time
adopt such interpretations of this Code as it deems
appropriate.
(3) ANNUAL CERTIFICATION OF COMPLIANCE. Within 10 days of becoming
an Access Person, and each year thereafter, each such person
will sign and return the compliance certification attached as
EXHIBIT D.
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The Tuscarora Investment Trust
Individuals Referenced in the Code of Ethics
August 28, 2000
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ACCESS PERSONS
None
INDEPENDENT TRUSTEES
C. Russell Bryan
John M. Day
Joseph T. Jordan, Jr.
COMPLIANCE OFFICER(S)
Margaret C. Landis, Compliance Officer
Benita W. Solomon, Compliance Analyst
ALTERNATE REVIEW OFFICER(S)
David R. Carr, Jr.
Lisa M. Gabriel
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EXHIBIT A
The Tuscarora Investment Trust
Quarterly Personal Securities Transaction Report
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Name of Reporting Calendar Quarter
Person: ___________________ Ended: _____________________
Date Report Due: ___________________ Date Submitted: _____________________
Securities Transactions* (Note: Transactions in both Pubic and Private (I.E.,
limited offerings) Covered Securities are required to be reported, unless
otherwise exempted under the Code.)
<TABLE>
<CAPTION>
----------------- ----------------- ------------- ------------------ --------------- ---------- ---------------------
Date of Name of Issuer No. of Principal Type of Price Name of Broker,
Transaction and Shares (if Amount, Maturity Transaction Dealer or Bank
Title of applicable) Date and (e.g., buy, Effecting
Covered Security Interest Rate sell or other) Transaction
(if applicable)
<S> <C> <C> <C> <C> <C> <C>
----------------- ----------------- ------------- ------------------ --------------- ---------- ---------------------
----------------- ----------------- ------------- ------------------ --------------- ---------- ---------------------
----------------- ----------------- ------------- ------------------ --------------- ---------- ---------------------
----------------- ----------------- ------------- ------------------ --------------- ---------- ---------------------
</TABLE>
- I had no transactions involving Covered Securities during the preceding
calendar quarter that were required to be reported.
- I had transactions involving Covered Securities during the preceding
calendar quarter and I have attached a copy of my most recent account
statement, which contains all of the information listed above.
* The report or recording of any transaction noted above will not be
construed as an admission that I have beneficial ownership of one or
more of the Covered Securities reported above.
Securities Accounts
If you established a securities account during the quarter, please provide the
following information:
<TABLE>
<CAPTION>
---------------------------------------------------------------------------------------------------------------------
Name of Broker, Dealer or Bank Date Account was Established Name(s) on and Type of Account
---------------------------------------------------------------------------------------------------------------------
<S> <C> <C>
---------------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------------------
---------------------------------------------------------------------------------------------------------------------
</TABLE>
- I did not establish a securities account during the preceding calendar
quarter.
I certify that I have included on this report all transactions in Covered
Securities and accounts required to be reported pursuant to the Code of Ethics.
------------------------------------- --------------------------------
(Signature) (Date)
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EXHIBIT B
The Tuscarora Investment Trust
Initial Holdings Report
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Name of Reporting Date Person Became
Person: ___________________ Subject to the Code:__________________
Date Report Due: ___________________ Date Submitted: __________________
Information Provide [NOTE: Date person became subject to
as of: ___________________ Code and as of date should be the same.]
Securities Holdings* (Note: Holdings in both Pubic and Private (I.E., limited
offerings) Covered Securities are required to be reported, unless otherwise
exempted under the Code.)
<TABLE>
<CAPTION>
------------------------------------------------------ ------------------------ ------------------------------------
Name of Issuer and No. of Shares Principal Amount, Maturity Date
Title of Covered Security (if applicable) and Interest Rate (if applicable)
------------------------------------------------------ ------------------------ ------------------------------------
<S> <C> <C>
------------------------------------------------------ ------------------------ ------------------------------------
------------------------------------------------------ ------------------------ ------------------------------------
------------------------------------------------------ ------------------------ ------------------------------------
------------------------------------------------------ ------------------------ ------------------------------------
------------------------------------------------------ ------------------------ ------------------------------------
</TABLE>
- I have no holdings in Covered Securities to report.
- I have holdings in Covered Securities to report and I have attached a
copy of my most recent account statement, which contains all of the
information listed above.
* The report or recording of any holding in Covered Securities noted
above will not be construed as an admission that I have beneficial
ownership of one or more of the Covered Securities reported above.
Securities Accounts
<TABLE>
<CAPTION>
------------------------------------------------------------------------------------------
Name of Broker, Dealer or Bank Name(s) on and Type of Account
------------------------------------------------------------------------------------------
<S> <C>
------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------
------------------------------------------------------------------------------------------
</TABLE>
- I have no securities accounts to report.
I certify that I have included on this report all holdings in Covered Securities
and accounts required to be reported pursuant to the Code of Ethics.
------------------------------------- --------------------------------
(Signature) (Date)
-------------------------------------------------------------------------------
13
<PAGE>
EXHIBIT C
The Tuscarora Investment Trust
Annual Holdings Report
-------------------------------------------------------------------------------
Name of Reporting Calendar Year Ended:
Person: ___________________ __________________
Date Report Due: ___________________ Date Submitted: __________________
Information Provided [NOTE: Information should be current as
as of: ___________________ of a date no more than 30 days before
this report is submitted.]
Securities Holdings* (Note: Holdings in both Pubic and Private (I.E., limited
offerings) Covered Securities are required to be reported, unless otherwise
exempted under the Code.)
<TABLE>
<CAPTION>
----------------------------------------------- ------------------------ ------------------------------------
Name of Issuer and No. of Shares Principal Amount, Maturity Date
Title of Covered Security (if applicable) and Interest Rate (if applicable)
----------------------------------------------- ------------------------ ------------------------------------
<S> <C> <C>
----------------------------------------------- ------------------------ ------------------------------------
----------------------------------------------- ------------------------ ------------------------------------
----------------------------------------------- ------------------------ ------------------------------------
----------------------------------------------- ------------------------ ------------------------------------
----------------------------------------------- ------------------------ ------------------------------------
</TABLE>
- I have no holdings in Covered Securities to report for the year.
- I have holdings in Covered Securities to report and I have attached a
copy of my most recent account statement, which contains all of the
information listed above.
* The report or recording of any holdings in Covered Securities noted
above will not be construed as an admission that I have beneficial
ownership of one or more of the Covered Securities reported above.
Securities Accounts
<TABLE>
<CAPTION>
-------------------------------------------- -------------------- ------------------------------------------
Name of Broker, Dealer or Bank Date Account Was Name(s) on and Type of Account
Established
-------------------------------------------- -------------------- ------------------------------------------
<S> <C> <C>
-------------------------------------------- -------------------- ------------------------------------------
-------------------------------------------- -------------------- ------------------------------------------
</TABLE>
- I have no securities accounts to report for the year.
I certify that I have included on this report all holdings in Covered Securities
and accounts required to be reported pursuant to the Code of Ethics.
------------------------------------- --------------------------------
(Signature) (Date)
-------------------------------------------------------------------------------
14
<PAGE>
EXHIBIT D
The Tuscarora Investment Trust
Compliance Certification
-------------------------------------------------------------------------------
Initial Certification
I certify that I:
- have received, read and reviewed the Code of Ethics;
- understand the policies and procedures in the Code;
- recognize that I am subject to such policies and procedures;
- understand the penalties for non-compliance;
- will fully comply with the Code of Ethics; and
- have fully and accurately completed this Certification.
Signature: _________________________ Date Submitted: _______________________
Name: _________________________ Due Date: _______________________
(please print)
-------------------------------------------------------------------------------
Annual Certification
I certify that I:
- have received, read and reviewed the Code of Ethics;
- understand the policies and procedures in the Code;
- recognize that I am subject to such policies and procedures;
- understand the penalties for non-compliance;
- have complied with the Code of Ethics and any applicable reporting
requirements during this past year;
- have fully disclosed any exceptions to my compliance with the Code below;
- will fully comply with the Code of Ethics; and
- have fully and accurately completed this Certification.
Exceptions:
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
-------------------------------------------------------------------------------
Signature: _________________________ Date Submitted: _______________________
Name: _________________________ Due Date: _______________________
(please print)
15
