Preclearance of All Personal Securities Transactions Sample Clauses

Preclearance of All Personal Securities Transactions. An Access Person Account may not purchase or sell directly or indirectly, any security in which the account has, or by reason of such transaction acquires, beneficial ownership (“Beneficial Ownership”) unless the Access Person obtains preclearance from the Compliance Officer or someone delegated by the Compliance Officer to administer these procedures if the Compliance Officer is unavailable. An Access Person Account is considered to have a Beneficial Ownership in securities if the Access Person directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise has or shares a direct or indirect “pecuniary interest” in such securities. While the definition of “pecuniary interest” is complex, an Access Person generally has a pecuniary interest in securities if such Access Person has the opportunity, directly or indirectly, to profit or share in any profit derived from a transaction in the securities. Access Person Accounts include securities or commodities accounts maintained at any financial institution where an Access Person has a Beneficial Ownership interest in securities in the account. Subject to Section III of this Appendix A, the following securities do not require preclearance: direct obligations of the Government of the U.S., bankers’ acceptances, bank certificates of deposit, commercial paper, ETF’s, high quality short-term debt instruments, including repurchase agreements, and shares issued by registered investment companies not advised or sub-advised by Trading Advisor.