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.
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.
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.
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.
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
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.
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.
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
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.
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
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
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
Access persons must obtain approval from Financial Tailor, Inc. before they acquire any
beneficial ownership in any initial public offerings or limited offerings.
Access person means any supervised person who has access to nonpublic information regarding
any client's purchase or sale of securities, or nonpublic information regarding the portfolio
holdings of any reportable fund, or who is involved in making securities recommendations to
clients, or who has access to recommendations that are non-public. Since the primary function
of Financial Tailor, Inc. is to provide investment advice, it can be assumed that all employees and
principals are access persons.
Automatic Investment Plan means a program in which regular periodic purchases or
withdrawals are made automatically in investment accounts in accordance with a
predetermined schedule and allocation. An automatic investment plan includes a dividend
Beneficial Ownership - any person who, directly or indirectly, through any contract,
arrangement, understanding, relationship or otherwise, has or shares a direct or indirect
pecuniary interest in the equity securities.
Federal securities laws means the Securities Act of 1933, the Securities Exchange Act of 1934,
the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the Investment Advisers
Act of 1940, Title V of the Gramm-Leach-Bliley Act, any rules adopted by the Commission under any of these statutes, the Bank Secrecy Act as it applies to funds and investment advisers, and any rules adopted thereunder by the Commission or the Department of the Treasury.
Fund - an investment company registered under the Investment Company Act.
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.
Limited offering - an offering that is exempt from registration under the Securities Act of
1933 pursuant to section 4(2) or section4(6) or pursuant to Rule 504, Rule 505, or Rule 506 of
the Investment Advisers Act of 1940.
Purchase or sale of a security includes, among other things, the writing of an option to purchase
or sell a security.
Reportable Fund - Any fund in which Financial Tailor, Inc. is the adviser or any fund whose
principal underwriter controls Financial Tailor, Inc.
Any fund whose investment adviser or principal underwriter controls Financial Tailor, Inc., is
controlled by Financial Tailor, Inc., or is under common control with Financial Tailor, Inc. For
purposes of this section, control has the same meaning as it does in section 2(a)(9) of the
Investment Company Act of 1940.
Reportable Security - a security as defined in section 202(a)(18) of the Investment Advisers
Act of 1940 (15 U.S.C. 80b-2(a)(18)), except that it 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; Bankers' acceptances, bank certificates of deposit,
commercial paper and high quality short-term debt instruments, including repurchase
agreements; Shares issued by money market funds; Shares issued by open-end funds other than
reportable funds; and Shares issued by unit investment trusts that are invested exclusively in
one or more open-end funds, none of which are reportable funds.