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Activities Please see the Advisers Personal Trading Policy FAQ (the Personal Trading Policy FAQ) found on the Legal Compliance Wiki page. On an annual basis thereafter, all Adviser employees must report all of their Personal Accounts (including accounts of Covered Persons) in which Reportable Securities are or could be maintained and all current holdings in Reportable Securities on the Annual Trading Report in iComply. All professionals who are certified by Blockchain Institute of Technology recognize that such certification is a privilege that must be both earned and maintained. Page 16 of 23 It is noted that managed accounts, should they be approved by the CCO, are exempt from both the Code s preclearance, trading restrictions for transactions effected in said managed account, as well the initial and annual holding disclosure requirement of the. 6.1 Duplicate Copies of Statements to Adviser All Adviser employees and Covered Persons must direct their brokers or custodians or any persons managing any Adviser employees or Covered Persons account in which any Reportable Securities are held or could be held to supply the CCO. A request for preclearance must be made electronically by completing the Advisers electronic personal trade request form and submitting it for approval to Compliance in advance of the completed transaction.
Any employee who violates the Advisers prohibition on front-running or who engages in other types of behavior prohibited by the Code will be subject to immediate disciplinary action, which may include suspension or discharge from the Adviser and/or suspension or discharge from any affiliate. 4.11 Note on Exceptions Notwithstanding the forgoing, the CCO may review an Adviser employees or Covered Persons personal trade request(s) that do not comply with, or fall outside of, the parameters set forth in the Code, in order to determine whether an exception to one.
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However, transactions and holdings in municipal bonds continue to require quarterly and annual reporting to Compliance respectively.1 Note on Managed Accounts As noted above, transactions effected in, and the holdings of, any account over which an Adviser employee or Covered Person has no direct. As noted above, transactions involving private placements and investment opportunities of limited availability are applied towards the permissible monthly purchases and sales transaction limit. The Adviser has limited the number of Approved Brokers at which Adviser employees and Covered Persons may maintain Personal Accounts to the following Approved Brokers: (i) Charles Schwab; (ii) Citibank (iii) E*trade; (iv) Fidelity; (v).P. It is noted that in the event the CCO grants such an exception, such securities may be subjected to a mandatory holding period, to be determined by the Two Sigma Legal Compliance Department in its sole discretion. Morgan; (vi) Merrill Lynch; (vii) Morgan Stanley Smith Barney; (viii) Scottrade; (xi) TD ameritrade; (x) UBS; (xi) usaa; (xii) Vanguard; and (xiii) Wells Fargo. A Covered Person must (i) transfer the account to their current employers 401(k) plan or (ii) transfer it to an IRA at one of the Approved Brokers.
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