2019 ANNUAL COMPLIANCE CERTIFICATION

 

Instructions:  Annually every firm associate must complete the PICI 2019 ACC (Annual Compliance Certification) as part of our Compliance Program.  This form must be completed in one session, if you close the form prior to completion, it will NOT save your answers and you will be required to enter everything over again.  Any questions that require additional reporting, need to be done on a Compliance Reporting Page (CRP) and must be submitted the same day as the ACC is transmitted.  An electronic CRP is available in the Forms & Documents section. DEADLINE TO COMPLETE IS 4-1-2019 Once completed and transmitted, please continue with the remaining compliance program requirements.  Upon completion of all elements, sign and forward via email the Annual Compliance Program Attestation form. For those associates in branch offices who report to an OSJ manager, send your certification to your OSJ manager who will sign and forward to the Home Office. If you have any questions, please contact Sherry Abbott @ 218.681.7344 or sabbott@polarinvest1.com.

PERSONAL INFORMATION Name:        Rep ID:   Office: Has your business address/phones/fax changed?      Yes (notify HO)    No Has your resident address/phones/fax changed?       Yes (notify HO)    No Alternate Email Address:  Accept text messaging in emergency situations : Yes   No     Cell phone :   COMPUTER-CYBERSECURITY If your computer requires a password to logon, indicate it here:   If your email program requires a password to access, indicate here: (i.e.,Windows Live, Outlook, etc.):  (this is not the password for your email address)      The following information is required to be reported annually per the firm's cybersecurity policy: Computer Make & Models : (Ex:  Dell-Inspirion; HP Laptop-Pavillion) Operating System :   (Ex:  Windows 7, Windows 8, or Windows 10)  Antivirus - Security Software : (Ex: Norton 360 Live) Antivirus - Security Software Version Number :   (Ex: 1.22.33.44.5) Does security offer up-to-date or live updates and do you subscribe to that?    COMPLIANCE QUESTIONS   Have you ever: (any statement from #1- #23 answered “yes” must be fully explained on a CRP unless previously disclosed)   Yes No 1. commingled client funds with your personal funds? Yes No 2. cashed a client check? Yes No 3. held a client asset beyond the close of the next business day? Yes No 4. asked a client to make a check payable to you? Yes No 5. signed a name other than your own on any document? Yes No 6. guaranteed a client against a loss? Yes No 7. recommended a security to a client that was not in line with the client’s objectives or time horizons? Yes No 8. effected an unauthorized transaction in a client account? Yes No 9. misrepresented information to a client or omitted material facts from a client? Yes No 10. recommended a transaction solely for the purpose of generating a commission? Yes No 11. effected a transaction for which you are not properly licensed or registered? Yes No 12. executed a transaction in a security subject to Rule 15c2-6 (Penny Stock Rule) without proper documentation? Yes No 13. made a settlement with a client without authorization from your firm? Yes No 14. shared commissions with an unlicensed person or with anyone without prior firm approval? Yes No 15. sold a product away from the firm, including insurance products without authorization? Yes No 16. participated in the profits of a client account? Yes No 17. given investment advice without being properly licensed? Yes No 18. represented to a client, or anyone else, your employment status to be other than what it actually is (PICI independent contractor, registered representative), this includes verbal and written communication, including titles used on letterhead, business cards and websites? Yes No 19. been or are you currently the subject of a client complaint that has not been properly disclosed to the firm? Yes No 20. been or are you currently the subject of an investigation by a governmental body or self-regulatory organization or law enforcement agency which has not been properly disclosed to PICI’s compliance department? Yes No 21. borrowed money from a client or loaned money to a client? Yes No 22. sent a written communication to a client or caused a written communication to be sent or used (including electronic communication) which was not approved by PICI’s compliance department prior to first use? Yes No 23. been arrested for ANY offense that has not been disclosed or reported on Form U4 if applicable.   Do you:   Yes No 24. have any outside accounts for family members or yourself that are not marked for duplicate confirms going to PICI’s compliance department (other than PICI accounts)? Yes No 25. have a separate corporate or personal checking account into which you deposit your commission checks and pay all of your business expenses? Yes No 26. know that the above checking account must never accept checks from clients? Yes No 27. know that the receipts and disbursements in this account are subject to review by the firm and any regulatory agency? Yes No 28. have any outside agreements or empowerments?   (if yes, complete CRP if you have not done so in the past) Yes No 29. have any outside affiliations?                     (if yes, complete CRP if you have not done so in the past) Yes No 30. have any income not related to PICI-including spousal?  (if yes, complete CRP if you have not done so in the past)   Miscellaneous   Yes No 31. are you using a name other than Polar Investment Counsel, Inc. in conducting any securities  or insurance or advisory business?  (if yes, complete the DBA Disclosure form unless one is already on file) Yes No 32. are you or your spouse an officer, owner or director of any corporation?  If yes, enter the following:  Name of corporation:  Tax Payer ID: Ownership Percentage: Yes No 33. have you made any political contribution in the past year that you did not seek prior approval for?    (if yes, complete a CRP) Yes No 34. are you aware that firm policy states that contributions in excess of $100 to any one person or party without prior written permission from the compliance director are prohibited?   Outside Business Activity   Yes No 35. are you involved in any outside business activities that is not reported on your current Form U4 filing snapshot that was recently reviewed?       Note:  Please be sure to review your Form U4 snapshot before answering above question. Note:  If you answered YES, an updated OBA form is required which can be obtained from the Forms & Docs page.   I understand that I need firm (PICI) approval prior to entering into any outside business activity whatsoever (including any material political activity) and that failure to disclose outside activity or to seek approval for same will subject me to possible fines, censures or even a bar from the industry.        Enter Initials acknowledging statement       COMPLIANCE CERTIFICATION   I certify that:  (A "yes" response signifies your certification of each item below; any statement answered “no” must be fully explained on a CRP)   Yes No 36. I have read and am familiar with all of PICI's written supervisory and compliance manuals (WSP, HO P&P, etc.) and abide by the rules and regulations set forth in it and all other policies and procedures presented on the firms website or otherwise.  I further agree to read and abide by any and all revisions or updates for above when presented. Yes No 37. I have not engaged in any private securities transaction in any manner other than that permitted in the WSP Manual and approved in writing by PICI. Yes No 38. I have not opened a personal securities account or placed an order for the purchase or sale of securities with another broker-dealer.  If I have, I have complied with the requirements set forth in the WSP Manual and have notified the PICI Home Office Compliance Principal. Yes No 39. I have not registered as a Registered Representative with any unaffiliated broker-dealer without first receiving written approval from the PICI Home Office Compliance Principal. Yes No 40. I have not engaged in any insurance business, financial planning or registered as an associated person or investment advisor with any Federal or State regulatory body without first receiving written approval from the PICI Home Office Compliance Principal. Yes No 41. I have not used any sales literature, advertising or business cards without having first submitted such material to the PICI Home Office Compliance Principal. Yes No 42. I have read and understand PICI’s policy concerning “insider trading” and am in compliance with that policy. Yes No 43. I have recently reviewed my FINRA Form U4 application and have determined it is presently accurate and if there are any changes to items contained on Form U4, I understand it’s my obligation to report those changes to the PICI Home Office Compliance Principal or designee.  If I am an unregistered (sales assistant) or other unregistered person affiliated with the firm, I understand that my branch office personnel file must contain an accurate paper version of the then current Form U4 and further understand it’s my obligation to report those changes to the PICI Home Office Compliance Principal or designee.     Enter your initials here to attest to reviewing Form U4   Yes No 44. I have read and understand PICI’s policy regarding “money laundering” and am in compliance with that policy. Yes No 45. I have read and understand PICI’s policy regarding the use of email and am in compliance with that policy. Yes No 46. I have read and understand PICI’s policy regarding obtaining and maintaining the proper computer, security software and electronic equipment which may or may not include monthly or yearly subscriptions, all of which is at my expense. Yes No 47. I have reviewed and am following PICI’s procedures for accepting and processing all client assets including checks and securities. Yes No 48. I have not stolen and will not steal another person’s money or possessions. Yes No 49. I understand that electronic submission of acknowledgements constitute the same legal response as a written signature or initials. Yes No 50. I agree to accept instructions via email message, verbal (phone or recorded message), fax transmission or delivery service, such as but not limited to: USPS Certified, Fed-Ex, etc.  I further agree to acknowledge such deliveries when required. Yes No 51. I have conducted my business and will continue to conduct my business in accordance with my Letter of Operational & Supervisory Understanding (LOSU) that is on file from the previous year(s).  By initialing below, I attest to abide by that letter unless presented with a revised letter for signature by the Home Office. Enter your initials here to attest to above   Yes No 52. I have read FINRA Rule 2263-Arbitration Disclosure to Associated Persons Signing or Acknowledging Form U4 as was presented by the firm.  By initialing below, I attest that I am aware that by signing the Form U4, I acknowledge that it contains a predispute arbitration clause. Enter your initials here to attest to statement   Yes No 53. I have not created a social networking account under the name of Polar Investment Counsel Inc. and I have not solicited via a social networking website. My immediate family is also aware of the policy I must follow and understand no postings can be made regarding PICI and solicitation or recommendations of securities.  Enter initials here to attest to statement   Yes No 54. I have not filed for bankruptcy, had any judgments, liens or compromises with creditors filed against me that I have not reported on my Form U4 or advised the firm of.  Enter initials here to attest to statement Yes No 55. I have not performed any activities for which I am not properly licensed for and as is reported on my Form U4 which has been reviewed. .  Enter initials here to attest to statement Yes No 56. I have read and understand the firm's cyber security policy and will promptly notify the HO of any cyber attacks on my computers, maintain the proper security software that is required and report any changes to my computer information as it happens. Enter initials here to attest to statement NFA  SELF-EXAM  ATTESTATION  (For NFA Registered Brokers Only) If you are not sure if you are registered, please contact the Home Office   The following attestation is for National Futures Association (NFA) registered brokers only:   Review the NFA Self-Exam Checklist for IB’s (link located on the Compliance website, Forms & Documents page, NFA Forms section).  After reviewing, check the box below indicating that you have done so and certify the following statement:   Appropriate supervisory personnel for Polar Investment Counsel, Inc. have reviewed and evaluated the current procedures of PICI using the NFA Self-Exam Checklist.  Based on that review, it appears that PICI’s current procedures are adequate to meet its supervisory responsibilities.    Check here to certify the above statement    Initial Here:     FOR ALL ASSOCIATES:   UNDER PENALTIES OF PERJURY I CERTIFY THAT THE FOREGOING INFORMATION IS TRUE AND CORRECT.   By entering my printed name below, I represent that I have personally completed this compliance certification and the electronic submission of my printed name below warrants the same legal binding as a written signature.   Printed Name   IMPORTANT - If you want a copy of this page for your records, you will need to use your browser print function at this time.  You will however, receive via email a copy of the electronic submission with your input responses from the Home Office.  Print that email for your records.   You will receive a confirmation page upon submission of this certification.  Be sure to print a copy of that confirmation for your records as proof you submitted the compliance certification.