PERSONAL TRADE definition
PERSONAL TRADE means the purchase or sale of Securities by an Access Person for any account in which they have Beneficial Ownership, or any account, other than an account of an advisory client of the Firm, “controlled” by an Access Person. An account is “Controlled” by an Access Person where that person decides what Securities transactions will be effected for the account, either by making recommendations to the account owner or by entering orders directly with the broker handling the account. At no time will a trade for an advisory client of the Firm be deemed a Personal Trade.
PERSONAL TRADE. ASSISTANT" (PTA) is provided by Dataware Solutions, and is an electronic tool that facilitates pre-clearance and reporting of personal trades, completion of required Certifications, and holdings of all access and related persons brokerage accounts.