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by Investment Management Firm Disclosure Report of Political (NJ Department of Treasury)

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Completed form should be submitted electronically to:
doi.compliance@treas.state.nj.us
1
Form Effective 8/16/12
STATE OF NEW JERSEY
DEPARTMENT OF THE TREASURY
DIVISION OF INVESTMENT
Disclosure Report of Political Contributions
by Investment Management Firm
Pursuant to N.J.A.C. 17:16-4.6, promulgated by the State Investment Council
(“Council”), each investment management firm seeking to be engaged to provide
investment management services to the State of New Jersey is required to disclose prior
to engagement, on a form provided by the Division of Investment (the “Division”), all
political contributions and payments to political parties made or paid by the firm, its
parent, or any other controlling person or entity, any investment management
professional associated with the firm, any political action committee controlled by any of
the above persons or entities, or any third party solicitor associated with the firm. Each
investment management firm that is engaged by the Division is further required to make
quarterly disclosures by the last day of the month following the end of each calendar
quarter during the term of the engagement; provided, however, that no report is required
for any calendar quarter in which the investment management firm has no information
that is required to be reported or updated. (All terms used in this Form have the
definitions set forth in the Appendix to this Form.)
Name of Investment Management Firm:
Disclosure Report Period (check one):
□ Initial Report:
From:
(Two years prior to date of engagement)
Through:
(Date of engagement)
□ Quarterly Report:
From:
(First day of calendar quarter)
Through:
(Last day of calendar quarter)
Form effective 8/16/12
2
Part 1: Designation of Investment Management Professionals
Please provide, in the table below, the names of those persons who qualify as “investment
management professionals,” using the attached definition, and a brief description of the
activities that cause such person to be an investment professional (e.g., investment
manager, advisor/manager to investment management entity, financial advisor/consultant,
client development, solicitation of business, supervisor, member of executive or
management committee).
Attach additional sheets, if necessary.
Name of Investment Professional Description of Activities
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
Check here if there are no changes from the investment professionals previously
designated by the investment management firm: □
Check here if investment management professionals are listed on a separate page: □
Form effective 8/16/12
3
Part 2: List of Political Contributions and Payments to Political Parties
Please provide the requested information in the following table with respect to all
political contributions and payments to political parties made by:
1. The investment management firm, its parent company, or any other person or
entity that controls the investment management firm;
2. Any investment management professional listed in Part 1;
3. Any third party solicitor associated with such investment management firm
1
;
4. Any political action committee controlled by the investment management firm, its
parent company, or any other entity that controls the investment management
firm, or by an investment management professional of such investment
management firm or controlling entity; or
5. Any individual or entity for the 12-month period prior to such individual or entity
becoming an investment management firm, investment management professional
or third party solicitor.
Political contributions made to State officials for whom the contributor was/is entitled to
vote need not be reported, so long as such contributions did/do not exceed $250.00 per
State official per election. Payments to a political party need not be reported, so long as
such payments did/do not exceed $250.00 per political party per year. Political
contributions and payments to a political party listed on an earlier Disclosure Report need
not be restated on this Disclosure Report.
Attach additional sheets, if necessary.
Name and Address of
Person or Entity Making
Political Contribution or
Payment to Political
Party:
Name and Title of State Official or
Political Party Receiving Political
Contribution or Payment to
Political Party:
Amount and Date
of Political
Contribution or
Payment to Political
Party:
Check here if contributions or payments are listed on a separate page: □
1
A third party solicitor shall include any “indirect” solicitor known to be compensated by the “primary”
solicitor to solicit investment management business from the State or State official on behalf of the
investment management firm.
Form effective 8/16/12
4
Part 3: Exemptions from Disqualification Pursuant to N.J.A.C. 17:16-4.10
Pursuant to N.J.A.C. 17:16-4.10, an investment management firm will not be prohibited
from being engaged to provide investment management services to the State by virtue of
a political contribution or payment to a political party that would otherwise cause its
disqualification under N.J.A.C. 17:16-4.3 if: (1) the investment management firm
discovers such contribution or payment (not to exceed $250.00) within four months of the
date of contribution or payment and the contributor obtains a return of the contribution or
payment within 60 calendar days of the date of discovery; or (2) the violation of N.J.A.C.
17:16-4 caused by such contribution or payment was unintentional and inadvertent, and
the Council determines that the beneficiaries of the Pension and Annuity Funds, the State
taxpayers, and the public are best served by an exemption.
Only one exemption is available for each investment management professional or third
party solicitor (regardless of time period), and the investment management firm is
entitled to no more than two exemptions for every 12-month period.
Please provide the requested information in the following table with respect to all exempt
political contributions and payments to political parties.
Name and Address of
Person or Entity
Making Political
Contribution or
Payment to Political
Party:
Name and Title of State
Official or Political Party
Receiving Political
Contribution or Payment
to Political Party:
Amount and
Date of Political
Contribution or
Payment to
Political Party:
Date of
Discovery /
Date of
Return of
Political
Contribution
or Payment to
Political
Party:
Date of
Exemption:
Form effective 8/16/12
5
Part 4: Information Regarding Third Party Solicitors
Please provide in the following tables the name and business address of any third party
solicitor, the services provided by the solicitor, the terms of compensation for such
services, and the total dollar amount of payments made to the solicitor during the report
period. The disclosure below should include any “indirect” solicitor known to be
compensated by the “primary” solicitor to solicit investment management business from
the State or a State official on behalf of the investment management firm.
Attach additional sheets, if necessary.
Name and Business
Address of Solicitor:
Services Provided
by Solicitor:
Summary of
Terms of
Compensation
(indicate whether
payment is made
to primary or
indirect solicitor):
Total Dollar
Amount of
Payments Made to
Solicitor During
Report Period:
Check here if third party solicitors are listed on a separate page: □
Check here if supporting documentation is attached: □
Form effective 8/16/12
6
I hereby certify as an officer or authorized representative of the investment management
firm identified below that such investment management firm has not either directly or
indirectly, through or by any other person or any means whatsoever, done any act which
would violate the provisions of N.J.A.C. 17:16-4.3 or 4.4. I further certify that, to the
best of my knowledge and belief, the foregoing statements and disclosure made by me
are true, accurate and complete. I am aware that if any of the statements are willfully
false, I am subject to punishment.
Name of Investment Management Firm:
Signed:
Print Name:
Title:
Date: ________________________
Form effective 8/16/12
7
Appendix
DEFINITIONS
For purposes of this Disclosure Report, the following words and terms shall have the
following meanings, as provided in N.J.A.C. 17:16-4, unless the context clearly indicates
otherwise:
“Control” means the power to exercise a controlling influence over the management or
policies of an investment management firm or political action committee.
“Investment management firm” means one or more natural persons, corporations,
partnerships or other entities, incorporated or unincorporated, that provide investment
management services.
“Investment management professional” means:
1. Any person associated with an investment management firm who is primarily
engaged in the provision of investment management services;
2. Any person associated with an investment management firm involved in client
development or the solicitation of business for investment management services
from pension funds clients;
3. Any person associated with an investment management firm who is a supervisor
of any person described in 1 or 2 above, up through and including the Chief
Executive Office or similarly situated official; or
4. Any person associated with an investment management firm, its parent company,
or any other entity that controls the investment management firm, who is a
member of the executive or management committee of such firm or controlling
entity, or similarly situated officials, if any.
“Investment management services” means:
1. The business of making or recommending investment management decisions for
or on behalf of the State Pension and Annuity Fund clients;
2. The business of advising or managing a separate entity which makes or
recommends investment management decisions for or on behalf of the State
Pension and Annuity Fund clients; or
3. The provision of financial advisory or consultant services to State Pension and
Annuity Fund clients.
“Payment” means any gift, subscription, loan, advance, or deposit of money or anything
of value.
Form effective 8/16/12
8
“Political contribution” means any gift, subscription, loan, advance, or deposit of money
or anything of value made:
1. For the purpose of influencing any election for State office;
2. For the purpose of influencing any election for local office by a person who is
also (i) a State official or (ii) an employee or advisor of either the State or a State
official;
3. For payment of debt incurred in connection with any such election; or
4. For transition or inaugural expenses incurred by the successful candidate in any
such election.
“Political party” means any political party or political committee organized in this State,
including county and independent committees.
“State official” means any person (including any election or political action committee
for such person) who was, at the time of the political contribution, an incumbent,
candidate or successful candidate for Governor or for a seat in the Legislature.
Communication with a State official includes communication with the employees and
advisors of such official.
“Third party solicitor” means a third party lobbyist who solicits investment management
business through direct or indirect communication with a State officer, employee or
official on behalf of an investment management firm, but does not include any person
whose sole basis of compensation from the investment management firm is the actual
provision of legal, accounting, engineering, real estate or other professional advice,
services or assistance.
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Completed 13 August 2020

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