Code of Ethics
Financial Tailor, Inc. operates in a business that requires the trust of our clients and as a result we require our advisers to strive to maintain that trust by adhering to the guidelines set forth in this code. Our advisers are expected to always put client interests ahead of their own and to treat all of our clients with respect. The investment company act, the investment advisers act, and the rules adopted under these acts prohibit fraudulent and manipulative practices when advising clients or participating in the securities markets. These rules require adoption of a code of ethics designed to reasonably prevent "access persons" from engaging in prohibited practices. The code will be reviewed annually by the board of directors of Financial Tailor, Inc.
Adoption of Code of Ethics
- Standards of Business Conduct
- Financial Tailor Inc. upholds a fiduciary duty to all of its clients. This fiduciary duty is extended to all employees and principals of Financial Tailor, Inc. This means that the needs of the client are paramount and come before the needs of the business. Every adviser must follow the "prudent man" rule and not provide investment recommendations that a prudent man would not advise. Additionally, fiduciaries cannot withhold material information from their clients that would affect their investment decisions.
- Compliance with Securities Laws
- Financial Tailor, Inc. and all of its employees and principals must comply with all applicable securities laws. All employees and Principals must not employ any device, scheme, or artifice to defraud clients, and they may not make any untrue statements nor withhold or omit material facts that may influence the investment decision of any clients. Violation of any securities laws will not be tolerated.
- Personal Securities Transactions and Holdings
- All access persons must report securities transactions and holdings to the Chief Compliance Officer on an annual basis and within 10 days of becoming an access person. Reporting requirements are discussed in more detail in part B of the code of ethics
- Reporting Violations
- All supervised persons must report violations of the code of ethics promptly to the Chief Compliance Officer. Additionally, it is encouraged that if a crime was committed to contact regulatory enforcement officials
- Availability of Code of Ethics
- All supervised persons must be provided with a copy of the code of ethics and must acknowledge their receipt of the code of ethics in writing along with a signature and date the code was received.
- Content of Holdings Reports
- Holdings reports must include the title and type of security, and the corresponding ticker symbol or CUSIP number, number of shares, and principal amount of each reportable security in which the access person has any direct or indirect beneficial ownership. The report must also include the name of any broker-dealer or bank with which the access person maintains an account in which any securities are held for direct or indirect benefit. The report must also contain the date the report was submitted.
- Timing of Holdings Reports
- Access persons must report all holdings within 10 days after becoming an access person, and the information provided must be no more than 45 days prior to the date the report was submitted. Access persons must make these reports available on an annual basis beginning December 1st of the year they become an access person and on an annual basis afterwards, if December first is a non-business day, the report shall be due on the following business day. Information provided in the annual report must be no more than 45 days prior to the date the report was submitted.
- Transaction Reports
- Access persons must submit quarterly transaction reports to the Chief Compliance Officer. Quarterly transaction reports must contain the date of the transaction, the title, and the exchange symbol or CUSIP number, interest rate, and maturity date, number of shares, and principal amount of each reportable security involved, the nature of the transaction, the price at which the transaction was effected, the name of the broker-dealer or bank where the transaction was effected, and the date that the access person submitted the report. Each report must be submitted within 30 days of each calendar quarter.
- Exceptions from Reporting Requirements
- Access persons are exempt from reporting securities held in accounts when they have no direct or indirect control or influence. No transaction report is required when the transaction occurs as the result of an automatic investment plan. No transaction report is necessary if the report would duplicate information contained in broker trade confirmations or account statements that are held in the records of Financial Tailor, so long as the confirmations are received no later than 30 days after the end of the applicable calendar quarter.
- Review of Reports
- The Chief Compliance Officer after receiving reports will review the reports for unauthorized trading activity such as: Restricted Securities, IPOs, private placements, securities which may have been purchased based on insider information, front running, participating in bunched trades to the disadvantage of clients, or trading that is not in-line with advice provided to clients.
Pre-approval of Certain Investments
Access persons must obtain approval from Financial Tailor, Inc. before they acquire any beneficial ownership in any initial public offerings or limited offerings.