Dealing with Clients definition

Dealing with Clients. Other than securities issued by a mutual fund sponsored or advised by SIFE, no Access Person may knowingly sell any security or other asset or property to, or purchase any security or other asset property from, any client of SIFE. Short-Term Trading: While SIFE believes that the extent of personal securities trading should be left to an individual's judgment, consistent with his or her personal objectives, risk tolerance, and past practices, all Access Persons should be aware that short-term trading may increase the risk of problems arising under this Code. Accordingly, no purchase and sale, or sale and purchase, of the same or equivalent securities by an Access Person will be allowed: