REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933
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Pre-Effective Amendment No.
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Post-Effective Amendment No.
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47
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REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940
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Amendment No.
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48 |
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David A. Katz
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10 Bank Street, Suite 590
White Plains, New York 10606
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Carol A. Gehl, Esq.
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Godfrey & Kahn S.C.
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833 E. Michigan St., Suite 1800
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Milwaukee, Wisconsin 53202
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[
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immediately upon filing pursuant to paragraph (b)
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[
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on October 31, 2017 pursuant to paragraph (b)
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60 days after filing pursuant to paragraph (a)(1)
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on (date) pursuant to paragraph (a)(1)
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[
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75 days after filing pursuant to paragraph (a)(2)
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[
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on (date) pursuant to paragraph (a)(2) of Rule 485.
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This post-effective amendment designates a new effective date for a previously filed post- effective amendment.
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1
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4
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5
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7
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7
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8
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13
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13
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14
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15
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15
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16
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17
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18
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PN
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Annual fund operating expenses
(expenses that you pay each year as a percentage of the value of your investment)
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Management Fees
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0.75%
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Other Expenses
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0.44%
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Total Annual Fund Operating Expenses
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1.19%
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Less: Fee Waiver and/or Expense Reimbursement
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-0.20%
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Total Annual Fund Operating Expenses After Fee Waiver and/or Expense Reimbursement
(1)
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0.99%
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(1) |
Matrix Asset Advisors, Inc. (the “Advisor”), the Fund’s investment adviser, has contractually agreed to reduce its fees and/or pay Fund expenses (excluding acquired fund fees and expenses, leverage interest, taxes, brokerage commissions and extraordinary expenses) in order to limit the Fund’s total annual fund operating expenses to 0.99% of the Fund’s average net assets (the “Expense Cap”). The Expense Cap will remain in effect until at least October 31, 2018. The agreement may be terminated at any time, and without payment of any penalty, by the Fund’s Board of Directors (the “Board of Directors”) upon 60 days’ written notice to the Advisor. The agreement may not be terminated by the Advisor without the consent of the Board of Directors. The Advisor is permitted, with Board approval, to recoup fees waived and expenses reimbursed in the prior three fiscal years if such recoupment does not cause the Fund to exceed the lesser of (i) the Expense Cap in effect at the time of the waiver or reimbursement and (ii) the Expense Cap in effect at the time of recoupment. Currently, the Advisor has agreed not to seek reimbursement of such fee waivers and/or expense reimbursements.
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1 Year
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3 Years
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5 Years
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10 Years
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$101
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$358
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$635
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$1,425
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Investment Advisor
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Portfolio Manager
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Managed the Fund Since
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Matrix Asset Advisors, Inc.
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David A. Katz, President and Chief Investment Officer
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1996
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To Open Your Account
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To Add to Your Account
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Regular Account
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$1,000
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$100
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Retirement Account
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$500
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$100
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Automatic Investment Plan
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$500
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$100
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· |
the security no longer represents a value, as determined by the Advisor; or
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· |
there has been a fundamental change in the issuer’s balance sheet or results of operations so that it no longer meets the Fund’s financial or valuation criteria.
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· |
Are pursuing a long-term goal such as retirement;
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· |
Want to add an investment in undervalued stocks to their equity portfolio; and
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· |
Are willing to accept higher short-term risk along with higher potential for long-term growth of capital.
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Regular Mail
Matrix Advisors Value Fund, Inc.
c/o U.S. Bancorp Fund Services, LLC
P.O. Box 701
Milwaukee, WI 53201-0701
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Overnight Delivery
Matrix Advisors Value Fund, Inc.
c/o U.S. Bancorp Fund Services, LLC
615 E. Michigan Street, 3
rd
Floor
Milwaukee, WI 53202-5207
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Regular Mail
Matrix Advisors Value Fund, Inc.
c/o U.S. Bancorp Fund Services, LLC
P.O. Box 701
Milwaukee, WI 53201-0701
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Overnight Delivery
Matrix Advisors Value Fund, Inc.
c/o U.S. Bancorp Fund Services, LLC
615 E. Michigan Street, 3
rd
Floor
Milwaukee, WI 53202-5207
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Years Ended June 30,
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||||||
2017
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2016
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2015
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2014
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2013
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Net asset value, beginning of year
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$57.90
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$63.02
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$63.32
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$49.56
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$40.44
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Income (loss) from investment operations:
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||||||
Net investment income
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1.03
(a)
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1.27 (a)
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0.77 (a)
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0.68 (a)
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0.59 (a)
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Net realized and unrealized gain (loss) on investments
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9.47
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(5.49)
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(0.28)
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13.71
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9.26
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Total from investment operations
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10.50
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(4.22)
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0.49
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14.39
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9.85
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Less distributions:
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Dividends from net investment income
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(1.55)
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(0.90)
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(0.79)
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(0.63)
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(0.73)
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Paid-in capital from redemption fees
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0.00
(b)
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0.00 (b)
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0.00 (b)
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0.00 (b)
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0.00 (b)
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Net asset value, end of year
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$66.85
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$57.90
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$63.02
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$63.32
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$49.56
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Total return
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18.22%
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(6.66)%
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0.77%
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29.20%
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24.69%
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Ratios/supplemental data:
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||||||
Net assets, end of year (millions)
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$58.6
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$55.1
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$73.8
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$81.0
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$60.7
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Ratio of operating expenses to average net assets:
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||||||
Before expense reimbursement
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1.19%
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1.16%
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1.12%
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1.15 %
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1.18%
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After expense reimbursement
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0.99%
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0.99%
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0.99%
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0.99 %
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0.99%
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Interest expense
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—
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—
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—
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0.00 %(c)
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—
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Ratio of net investment income to average net assets:
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||||||
Before expense reimbursement
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1.40%
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2.03%
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1.09%
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1.06 %
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1.18%
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After expense reimbursement
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1.60%
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2.20%
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1.22%
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1.22 %
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1.37%
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Portfolio turnover rate
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22%
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15%
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12%
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41 %
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15%
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(a) |
Calculated using the average shares method.
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(b) |
Less than $0.01.
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(c) |
Interest expense was less than 0.01%.
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•
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Information we receive about you on applications or other forms;
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•
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Information you give us orally; and
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•
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Information about your transactions with us or others.
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MATRIX ADVISORS VALUE FUND, INC.
www.matrixadvisorsvaluefund.com
For investors who want more information about the Fund, the following documents are available free upon request:
Annual/Semi-Annual Reports:
Additional information about the Fund’s investments is available in the Fund’s annual and semi-annual reports to shareholders. In the Fund’s annual report, you will find a discussion of market conditions and investment strategies that significantly affected the Fund’s performance during its last fiscal year.
Statement of Additional Information:
The SAI provides more detailed information about the Fund and is incorporated by reference into this Prospectus.
To request and receive free copies of the annual and semi-annual reports or the SAI, or to request other information (including shareholder inquiries) and discuss your questions about the Fund, contact the Fund at:
Matrix Asset Advisors, Inc.
10 Bank Street, Suite 590
White Plains, NY 10606
Telephone (toll free): 1-866-209-1965
Or, on the Fund’s website at: www.matrixadvisorsvaluefund.com
You can review and copy information including the Fund’s reports and SAI at the Public Reference Room of the SEC in Washington, D.C. You can obtain information on the operation of the Public Reference Room by calling (202) 551-8090. Reports and other information about the Fund are also available:
·
Free of charge from the SEC’s EDGAR database on the
SEC’s Internet website at http://www.sec.gov.
·
For a fee, by writing to the Public Reference Room of the SEC,
Washington, D.C. 20549-1520.
·
For a fee, by electronic request at the following e-mail address:
publicinfo@sec.gov.
(The Fund’s SEC Investment Company Act file number is 811‑03758.)
|
Prospectus
MATRIX
ADVISORS
VALUE FUND, INC.
Ticker Symbol: MAVFX
Cusip: 57681T102
October 31, 2017
10 Bank Street, Suite 590
White Plains, NY 10606
The SEC has not approved or disapproved these securities or passed upon the accuracy or adequacy of this Prospectus. Any representation to the contrary is a criminal offense.
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2
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2
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8
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10
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14
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16
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17
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18
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20
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21
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22
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23
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24
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25
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27
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28
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29
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30
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33
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34
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1) |
67% or more of the Fund’s shares present at a shareholder meeting if the holders of more than 50% of the Fund’s outstanding shares are present in person or by proxy; or
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2) |
More than 50% of the Fund’s outstanding shares.
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1. |
Purchase any securities which would cause more than 5% of the Fund’s total assets at the time of such purchase to be invested in the securities of any issuer, but this limitation does not apply to obligations issued or guaranteed by the U.S. Government;
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2. |
Purchase any securities which would cause the Fund at the time of such purchase to own more than 10% of the outstanding voting securities of any class of any issuer, but this limitation does not apply to obligations issued or guaranteed by the U.S. Government;
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3. |
Purchase any securities which would cause 25% or more of the Fund’s total assets at the time of such purchase to be invested in the securities of issuers engaged in any one industry;
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4. |
Invest in companies for the purpose of exercising management or control;
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5. |
Purchase or sell real estate, although the Fund may invest in the readily marketable securities of companies whose business involves the purchase or sale of real estate;
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6. |
Purchase or sell commodities or commodities contracts;
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7. |
Purchase the securities of any investment company, except (i) in the open market where no profit to a sponsor or dealer other than customary brokerage commissions results from such purchases or (ii) if acquired in connection with a plan of reorganization;
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8. |
Purchase securities on margin;
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9. |
Effect short sales of any securities;
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10. |
Make loans, except by the acquisition of a portion of an issue of publicly traded bonds, debentures, notes, and other debt securities;
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11. |
Borrow money, except for temporary emergency purposes in amounts not in excess of 5% of the Fund’s total assets;
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12. |
Mortgage, pledge or hypothecate securities;
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13. |
Act as an underwriter of securities except insofar as the Fund might technically be deemed an underwriter for purposes of the 1933 Act upon the disposition of certain securities;
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14. |
Purchase or retain the securities of any issuer if the Fund’s officers or directors, or those of the Advisor, who each own 0.5% of the outstanding securities of such issuer, together own beneficially more than 5% of such securities; or
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15. |
Issue any class of securities senior to any other class of securities.
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Interested Director
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||||||||||
Name,
Address
(1)
and Year of
Birth
|
Position(s)
Held with
the Fund
|
Term of
Office
and Date
Elected
(2)
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Principal Occupation During
Past Five Years
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Number of
Portfolios
in Fund
Complex
(3)
Overseen
by Director
|
Other
Directorships
Held by Director
for the Past Five
Years
|
|||||
David A. Katz, CFA
(4)
(Born 1962)
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Director, President and Treasurer
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Since 1997
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Chief Investment Officer (1986 to present) and President (1990 to present) of the Advisor, and portfolio manager of the Fund (1996 to present).
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2
|
Trustee, Matrix
Advisors Funds
Trust (mutual fund)
(2016 (inception)
to present)
|
|||||
Independent Directors
|
||||||||||
T. Michael Tucker
(Born 1942)
|
Director and Chairman
|
Since 1997
|
Owner of T. Michael Tucker, a certified public accounting firm (1977 to 2005 and 2011 to present); formerly, Consultant, Carr Riggs & Ingram, LLP, a certified public accounting firm (2005 to 2011).
|
2
|
Trustee, Matrix
Advisors Funds
Trust (mutual fund)
(2016 (inception)
to present)
|
|||||
Larry D. Kieszek
(Born 1950)
|
Director
|
Since 1997
|
Retired; formerly Partner of Purvis, Gray & Company, LLP, a certified public accounting firm (1974 to 2015).
|
2
|
Trustee, Matrix
Advisors Funds
Trust (mutual fund)
(2016 (inception)
to present)
|
|||||
David S. Wyler
(Born 1969)
|
Director
|
Since 2016
|
Vice President of Business Development, iQ Media (audience intelligence firm) (May to September 2017); Senior Director of Sales at Simulmedia (TV targeting company) (2016 – 2017); Vice President of Business Development at Resonate (marketing intelligence firm) (2014 – 2016); Vice President Business Development, Experian (2013 – 2014); Vice President of Business Development for the AdTruth division of 41st Parameter (fraud prevention firm) (2012 to 2013); Senior Vice President and General Manager, The Nielsen Company (2008 to 2011); Senior Vice President, IAG Research (market research firm) (2004 to 2008).
|
2
|
Trustee, Matrix Advisors Funds Trust (mutual fund) (2016 (inception) to present)
|
(1)
|
The address of each Director is 10 Bank Street, Suite 590, White Plains, NY 10606.
|
(2)
|
Each Director will hold office for an indefinite term until the earliest of (i) the next meeting of shareholders, if any, called for the purpose of considering the election or re-election of such Director and until the election and qualification of his or her successor, if any, elected at such meeting, or (ii) the date of a Director’s death, resignation or retirement, or a Director is removed by the shareholders, in accordance with the Fund’s By-Laws, as amended, and Articles of Incorporation of the Fund, as amended.
|
(3)
|
The “Fund Complex” includes the Fund and series of Matrix Advisors Funds Trust.
|
(4)
|
“Interested person” of the Fund is defined in the 1940 Act. Mr. Katz is considered an “interested person” because of his affiliation with the Advisor.
|
Officers of the Fund
|
|||
Name, Address
(1)
and Year of Birth
|
Position(s) Held
with the Fund
|
Term of Office
and Date
Elected
(2)
|
Principal Occupation
During Past Five Years |
Steven G. Roukis, CFA
(Born 1967)
|
Senior Vice
President
|
Since 2000
|
Managing Director and Senior Portfolio Manager of the Advisor (2005 to present).
|
Lon F. Birnholz
(Born 1960)
|
Executive Vice
President and
Secretary
|
Since 2006
|
Senior Managing Director of the Advisor (1999 to present).
|
Jordan F. Posner
(Born 1957)
|
Senior Vice
President
|
Since 2006
|
Managing Director and Senior Portfolio Manager of the Advisor (2005 to present).
|
Steven Pisarkiewicz
(Born 1949)
|
Senior Vice
President
|
Since 2010
|
Senior Managing Director and Senior Portfolio Manager of the Advisor (2009 to present).
|
Jonathan M. Tom
(Born 1983)
|
Senior Vice
President
|
Since 2016
|
Chief Operating Officer of the Advisor (2015 to present); Head Fixed Income Trader (2011 to present); Equity Research Analyst (2005 to present).
|
Stephan J. Weinberger, CFA
(Born 1955)
|
Senior Vice
President
|
Since 2010
|
Managing Director and Senior Portfolio Manager of the Advisor (2010 to present).
|
Conall J. Duffin
(Born 1975)
|
Vice President,
Assistant Secretary,
Chief Compliance
Officer and AML
Compliance Officer
|
Since 2002
Since 2016
|
Chief Compliance Officer of the Advisor (2016 to present); Vice President of Marketing and Mutual Fund Services of the Advisor (2010 to present).
|
(1) |
The address of each Officer is 10 Bank Street, Suite 590, White Plains, NY 10606.
|
(2) |
Each Officer will hold office for an indefinite term until the date he or she resigns or retires or until his or her successor is elected and qualifies.
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Name and Position
|
Aggregate Compensation
from the Fund |
Total Compensation
from the Fund and Fund Complex
Paid to Directors
(1)
|
Mr. Tucker, Director
|
$3,000
|
$3,750
|
Mr. Kieszek, Director
|
$3,000
|
$3,750
|
Mr. Wyler, Director
|
$3,000
|
$3,750
|
(1) |
The “Fund Complex” includes the Fund and a single series of Matrix Advisors Funds Trust.
|
Name of Director
|
Aggregate Dollar Range of Equity Securities
Beneficially Owned in the Fund
(1)
|
Independent Directors
|
|
T. Michael Tucker
|
Over $100,000
|
Larry D. Kieszek
|
Over $100,000
|
David S. Wyler
|
$1 - $10,000
|
Interested Director
|
|
David A. Katz
|
Over $100,000
|
(1) |
Beneficial ownership is determined in accordance with Rule 16a-1(a)(2) under the Securities Exchange Act of 1934, as amended.
|
Name and Address
|
Percentage
Ownership
|
Type of Ownership
|
Charles Schwab & Co., Inc.
211 Main Street
San Francisco, CA 94105-1905
|
62.94%
|
Record
|
National Financial Services LLC
200 Liberty Street, One World Financial Center
New York, NY 10281-1003
|
10.06%
|
Record
|
David A. Katz
c/o Matrix Asset Advisors, Inc.
10 Bank Street, Suite 590
White Plains, NY 10606
|
8.28%
|
Beneficial
|
2017
|
2016
|
2015
|
|
Advisory Fees Accrued
|
$436,515
|
$480,281
|
$566,775
|
Advisory Fees Waived
|
($113,025)
|
($106,880)
|
($98,789)
|
Total Advisory Fees paid
to the Advisor
|
$323,490
|
$373,401
|
$467,986
|
Category of
Account
|
Total Number of
Accounts Managed
|
Total Assets in
Accounts Managed
|
Number of
Accounts for
which
Advisory Fee is
Based on
Performance
|
Assets in
Accounts for
which Advisory
Fee is Based on
Performance
|
Other Registered Investment Companies
|
0
|
$0
|
0
|
$0
|
Other Pooled Investment Vehicles
|
0
|
$0
|
0
|
$0
|
Other Accounts
|
503
|
$751.03 million
|
0
|
$0
|
2017
|
2016
|
2015
|
$25,146
|
$22,559
|
$23,790
|
2017
|
2016
|
2015
|
$0
|
$0
|
$0
|
Broker
|
Amount
|
JPMorgan Chase & Co.
|
$2,833,400
|
Wells Fargo & Co.
|
$2,548,860
|
Morgan Stanley
|
$1,203,120
|
2017
|
2016
|
22%
|
15%
|
Net Assets
|
=
|
NAV per Share
|
Shares Outstanding
|
||
$58,630,908
|
$66.85
|
|
877,084
|
Matrix Advisors Value Fund, Inc.
|
Fee Paid
|
Fiscal Year Ended June 30, 2017
|
$73,264
|
Fiscal Year Ended June 30, 2016
|
$81,052
|
Fiscal Year Ended June 30, 2015
|
$94,161
|
(i) |
Copies of its proxy voting policies and procedures.
|
(ii) |
A copy of each proxy statement received regarding client securities (maintained by the proxy voting service and/or Matrix Asset Advisors).
|
(iii) |
A record of each vote cast on behalf of a client (maintained by the proxy voting service and/or Matrix Asset Advisors).
|
(iv) |
A copy of any document created that was material to the voting decision or that memorializes the basis for that decision.
|
(v) |
A copy of each written request for proxy voting information and a copy of any written response by Matrix Asset Advisors to any request for proxy voting information.
|
(a)
|
Articles of Incorporation
|
||
(1)
|
Articles of Incorporation are herein incorporated by reference to the Registrant’s Post‑Effective Amendment No. 18 to the Registration Statement on Form N-1A, filed with the Securities and Exchange Commission (“SEC”) on October 29, 1998.
|
||
(2)
|
Articles of Amendment are herein incorporated by reference to the Registrant’s Post‑Effective Amendment No. 16 to the Registration Statement on Form N-1A, filed with the SEC on June 6, 1997.
|
||
(b)
|
Amended and Restated By-laws
are herein incorporated by reference to the Registrant’s Post‑Effective Amendment No. 25 to the Registration Statement on Form N-1A, filed with the SEC on October 28, 2004.
|
||
(c)
|
Specimen Share Certificate
is herein incorporated by reference to the Registrant’s Post‑Effective Amendment No. 18 to the Registration Statement on Form N-1A, filed with the SEC on October 29, 1998.
|
||
(d)
|
Investment Advisory Agreement
is herein incorporated by reference to the Registrant’s Post‑Effective Amendment No. 16 to the Registration Statement on Form N-1A, filed with the SEC on June 6, 1997.
|
||
(1)
|
First Amendment dated September 1, 2010 to Investment Advisory Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 34 to the Registration Statement on Form N-1A, filed with the SEC on October 29, 2010.
|
||
(e)
|
Underwriting Contracts
|
||
(1)
|
Form of Distribution Agreement
is herein incorporated by reference to the Registrant’s Post‑Effective Amendment No. 23 to the Registration Statement on Form N-1A, filed with the SEC on October 28, 2002.
|
||
(A)
|
First Amendment dated March 10, 2009 to the Distribution Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 32 to the Registration Statement on Form N-1A, filed with the SEC on October 30, 2009.
|
||
(f)
|
Bonus or Profit Sharing Contracts
– Not applicable.
|
||
(g)
|
Custody Agreement
is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 39 to the Registration Statement on Form N-1A, filed with the SEC on October 31, 2013.
|
||
(h)
|
Other Material Contracts
|
||
(1)
|
Powers of Attorney are herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 39 to the Registration Statement on Form N-1A, filed with the SEC on October 31, 2013.
|
||
(2)
|
Power of Attorney of David S. Wyler is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 45 to the Registration Statement on Form N-1A, filed with the SEC on October 28, 2016.
|
(3)
|
Operating Expenses Limitation Agreement dated September 1, 2010 is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 34 to the Registration Statement on Form N-1A, filed with the SEC on October 29, 2010.
|
||
(4)
|
Fund Accounting Servicing Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 39 to the Registration Statement on Form N-1A, filed with the SEC on October 31, 2013.
|
||
(5)
|
Form of Line of Credit Agreement is herein incorporated by reference to the Registrant’s Post‑Effective Amendment No. 28 to the Registration Statement on Form N-1A, filed with the SEC on October 28, 2005.
|
||
(6)
|
Fund Administration Servicing Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 39 to the Registration Statement on Form N-1A, filed with the SEC on October 31, 2013.
|
||
(A)
|
First Amendment to Fund Administration Servicing Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 43 to the Registration Statement on Form N-1A, filed with the SEC on October 28, 2015.
|
||
(7)
|
Transfer Agent Servicing Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 32 to the Registration Statement on Form N-1A, filed with the SEC on October 30, 2009.
|
||
(A)
|
Addendum dated June 2, 2009 to the Transfer Agent Servicing Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 32 to the Registration Statement on Form N-1A, filed with the SEC on October 30, 2009.
|
||
(B)
|
First Amendment dated September 1, 2010 to the Transfer Agent Servicing Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 35 to the Registration Statement on Form N-1A, filed with the SEC on October 27, 2011.
|
||
(C)
|
Second Amendment to the Transfer Agent Servicing Agreement is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 43 to the Registration Statement on Form N-1A, filed with the SEC on October 28, 2015
|
||
(i)
|
Legal Opinion
|
||
(1)
|
Opinion and Consent of Counsel is herein incorporated by reference to the Registrant’s Post‑Effective Amendment No. 18 to the Registration Statement on Form N-1A, filed with the SEC on October 29, 1998.
|
||
(j)
|
Consent of Independent Registered Public Accounting Firm
– filed herewith.
|
||
(k)
|
Omitted Financial Statements
– None.
|
||
(l)
|
Agreement Relating to Initial Capital
– no undertaking in effect.
|
||
(m)
|
Rule 12b-1 Plan
– Not applicable.
|
||
(n)
|
Rule 18f-3 Plan
– Not applicable.
|
||
(o)
|
Reserved.
|
||
(p)
|
Codes of Ethics
|
(1)
|
Joint Code of Ethics
for Matrix Advisors Value Fund, Inc., Matrix Advisors Funds Trust and Matrix Asset Advisors, Inc. – filed herewith.
|
|
(2)
|
Code of Ethics
for Quasar Distributors, LLC. is herein incorporated by reference to the Registrant’s Post-Effective Amendment No. 41 to the Registration Statement on Form N-1A, filed with the SEC on October 27, 2014.
|
(a)
|
Quasar Distributors, LLC, the Registrant’s principal underwriter, in addition to the Matrix Advisors Value Fund, Inc., acts as principal underwriter for the following investment companies:
|
Academy Funds Trust
|
LoCorr Investment Trust
|
Advisors Series Trust
|
Lord Asset Management Trust
|
Aegis Funds
|
MainGate Trust
|
Allied Asset Advisors Funds
|
Managed Portfolio Series
|
Alpha Architect ETF Trust
|
Manager Directed Portfolios
|
Alpine Equity Trust
|
Matrix Advisors Fund Trust
|
Alpine Income Trust
|
Matrix Advisors Value Fund, Inc.
|
Alpine Series Trust
|
Merger Fund
|
Amplify ETF Trust
|
Monetta Trust
|
Angel Oak Funds Trust
|
Nicholas Equity Income Fund, Inc.
|
Barrett Opportunity Fund, Inc.
|
Nicholas Family of Funds, Inc.
|
Bridge Builder Trust
|
Oaktree Funds
|
Bridges Investment Fund, Inc.
|
Permanent Portfolio Family of Funds
|
Brookfield Investment Funds
|
Perritt Funds, Inc.
|
Brown Advisory Funds
|
PRIMECAP Odyssey Funds
|
Buffalo Funds
|
Professionally Managed Portfolios
|
CG Funds Trust
|
Prospector Funds, Inc.
|
DoubleLine Funds Trust
|
Provident Mutual Funds, Inc.
|
ETF Series Solutions
|
Rainier Investment Management Mutual Funds
|
Evermore Funds Trust
|
RBB Fund, Inc.
|
First American Funds, Inc.
|
RBC Funds Trust
|
FundX Investment Trust
|
Series Portfolio Trust
|
Glenmede Fund, Inc.
|
Sims Total Return Fund, Inc.
|
Glenmede Portfolios
|
Stone Ridge Trust
|
GoodHaven Funds Trust
|
Stone Ridge Trust II
|
Greenspring Fund, Inc.
|
Stone Ridge Trust III
|
Guinness Atkinson Funds
|
Stone Ridge Trust V
|
Harding Loevner Funds, Inc.
|
Thompson IM Funds, Inc.
|
Hennessy Funds Trust
|
TrimTabs ETF Trust
|
Horizon Funds
|
Trust for Professional Managers
|
Hotchkis & Wiley Funds
|
Trust for Advised Portfolios
|
Intrepid Capital Management Funds Trust
|
USA Mutuals
|
IronBridge Funds, Inc.
|
Wall Street EWM Funds Trust
|
Jacob Funds, Inc.
|
Westchester Capital Funds
|
Jensen Portfolio, Inc.
|
Wisconsin Capital Funds, Inc.
|
Kirr Marbach Partners Funds, Inc.
|
YCG Funds
|
LKCM Funds
|
(b)
|
To the best of the Registrant’s knowledge, the directors and executive officers of Quasar Distributors, LLC are as follows:
|
(c)
|
Not applicable.
|
MATRIX ADVISORS VALUE FUND, INC.
|
||
By: /s/ David A. Katz
|
||
David A. Katz
|
||
President
|
Signature
|
Title
|
|
/s/ David A. Katz
|
Director, President and Treasurer
|
|
David A. Katz
|
||
/s/ T. Michael Tucker*
|
Director
|
|
T. Michael Tucker
|
||
/s/ Larry D. Kieszek*
|
Director
|
|
Larry D. Kieszek
|
||
/s/ David S. Wyler*
|
||
David S. Wyler
|
Director
|
|
*Signed by
|
||
/s/ David A. Katz
|
||
David A. Katz
|
||
Attorney in Fact pursuant to Powers of Attorney duly executed by Messrs. Tucker and Kieszek and
filed with the Registrant’s Post-Effective Amendment No. 39 to the Registrant’s Statement on Form N-1A with the SEC on October 31, 2013 and executed by Mr. Wyler and filed with the Registrant’s Post-Effective Amendment No. 45 on Form N-1A with the SEC on October 28, 2016.
|
Exhibit
Number
|
Description
|
|
(j)
|
Consent of Independent Registered Public Accounting Firm
|
|
(p)(1)
|
Joint Code of Ethics for Matrix Advisors Value Fund, Inc., Matrix Advisors Funds Trust and Matrix Asset Advisors Inc.
|
|
/s/
TAIT, WELLER & BAKER LLP
TAIT, WELLER & BAKER LLP
|
(1) |
Describes any issues arising under the Code or procedures since the last report to the board of directors, including, but not limited to, information about material violations of the Code or procedures and sanctions imposed in response to the material violations; and
|
(2) |
Certifies that each Fund has adopted procedures reasonably necessary to prevent access persons from violating the Code.
|
DATE
|
SHARES/
AMOUNT
|
SECURITY*
|
INTEREST
RATE/
MATURITY
DATE
(if applicable)
|
PRICE
|
BUY
|
SELL
|
NAME OF
BROKER OR
BANK USED
|
|
|
|
1. |
Include all transactions during the calendar quarter set forth above in “Covered Securities” in which you (or a member of your “Family/Household”) has “Beneficial Ownership,” as such terms are defined in the Code.
|
2. |
Report all transactions for all accounts except with respect to accounts over which you have no direct or indirect influence or control. You are also not required to report transactions effected pursuant to an “Automatic Investment Plan” as defined in the Code.
|
3.
|
A report on this form is required within 30 calendar days after the end of each quarter.
|
|
|
747 Third Avenue
|
Tel. (212) 486-2004
|
New York, NY 10017
|
Fax (212) 486-1822
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
2
|
I
|
INTRODUCTION
|
3
|
|
|
|
I.1 CODE OF ETHICS
|
3
|
|
I.2 "ACCESS PERSONS"
|
4
|
|
I.3 "BENEFICIAL OWNERSHIP"
|
5
|
|
|
|
|
II
|
PENALITIES |
6
|
|
|
|
II.1 VIOLATIONS OF THE CODE
|
6
|
|
II.2 PENALITIES
|
7
|
|
II.3 DISMISSAL AND/OR REFERRAL TO AUTHORITIES
|
8
|
|
|
|
|
III
|
EMPLOYEE TRADE PROCEDURES
|
9
|
|
|
|
III.1 PRE-CLEARANCE
|
9
|
|
III.2 TRAFDE REPORTS
|
10
|
|
III.3 POST-REVEIW
|
11
|
|
III.4 PRE-CLEARANCE AND REPORTING REQUIREMENTS
|
12
|
|
III.5 CONFIDENTIALITY | 12 | |
III.6 ACKNOWLEDGEMENT OF BROKERAGE ACCOUNTS | 12 | |
III.7 INITIAL AND ANNUAL HOLDINGS REPORTS | 13 | |
IV | RESTRICITONS | 14 |
IV.1 RESTRICTED SECURITIES | 14 | |
IV.2 SHORT-TERM TRADINGS PROFITS (60-DAY TRADING RULE) | 15 | |
IV.3 BLACKOUT PERIODS | 15 | |
IV.4 INSIDER TRADING | 15 | |
IV.5 MARKET TIMING | 15 | |
IV.6 INDEPENDENT RESEARCH | 16 | |
IV.7 GIFTS AND HOSPITALITY | 17 | |
IV.8 POLITICAL ACTIVITIES | 17 | |
IV.9 DIRECTORSHIPS AND OTHER OUTSIDE EMPLOYMENT | 19 | |
IV.10 PURCHASE AND SALES OF MUTUAL FUNDS ADVISED AND SUB-ADVISED BY MAA | 19 | |
V | REGULATORY REQUIREMENTS | 20 |
V.1 INVESTMENT ADVISERS ACT OF 1940 AND INVESTMENT COMPANY ACT OF 1940 | 20 | |
V.2 REGULATORY CENSURES | 20 | |
V.3 RECORDKEEPING | 20 | |
VI | ACKNOWLEDGMENT AND CERTIFICATION | 22 |
APPENDIX A-FOR ADVISORY PERSONS | 23 |
|
June 2011
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
3
|
I.1 Code of Ethics |
Matrix Asset Advisors, Inc. (MAA), as a registered investment adviser and adviser to the Matrix Advisors Value Fund, Inc. and each series of Matrix Advisors Funds Trust (each a “Fund” and collectively, the “Funds”), has an obligation to maintain a policy governing personal securities transactions and insider trading by its officers and employees. This Code of Ethics and Policy on Personal Securities Transactions and Insider Trading (“Code”) is adopted under Rule 17j-1 of the Investment Company Act and Rule 204A-1 under the Investment Advisers Act. This Code outlines the policies and procedures for such activities based on the recognition that a fiduciary relationship exists between MAA and its clients. All references in this Code to employees, officers, directors, accounts, departments and clients refer to those of MAA.
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
4
|
• |
has access to nonpublic information regarding clients' purchase or sale of securities,
|
• |
is involved in making securities recommendations to clients,
|
• |
has access to such recommendations that are nonpublic, or
|
• |
has access to nonpublic information regarding the portfolio holdings of affiliated mutual funds.
|
• |
accounts of immediate family members in the same household; and
|
• |
any other account, including but not limited to those of relatives and friends, over which you exercise investment discretion.
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
7
|
¾ |
Third minor offense – $1,000.00 fine to be donated to the Access Person’s charity of choice*.
|
¾
|
First substantive offense – Written notice;
|
¾ |
Second substantive offense – $1,000 or disgorgement of profits (whichever is greater) to be donated to the Access Person’s charity of choice*;
|
¾ |
Third substantive offense – $5000 fine or disgorgement of profits (whichever is greater) to be donated to the Access Person’s charity of
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
8
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
9
|
III.1 Pre-clearance | • | All Access Persons in the firm must pre-clear personal securities transactions as specified in Section III.4. |
• |
All pre-clearance requests (requests for prior approval) must be approved and signed by the Chief Investment Officer or a MAA Partner and submitted to the Chief Compliance Officer. It is the responsibility of the Access Person to ensure that the Chief Compliance Officer receives pre-clearance requests.
|
• |
At a minimum
, indicate the following information on your pre-clearance request –
|
• |
Requests may be submitted from 9:00 am (Eastern) until an hour before the market closes for the day. Responses will be made as soon as feasible.
|
• |
Pre-cleared trades are valid for same day trades only. No exceptions.
|
• |
Pre-clearance does not preclude the possibility of a potential conflict appearing after the execution of an employee trade. Trades will be screened for blackout violations and other conflicts, but month end review of each personal trade will reveal a conflict occurring after the trade is executed.
|
• |
It is the responsibility of each Access Person to ensure that the report has been received by the Chief Compliance Officer.
|
• |
Monthly Trade Reports (in lieu of quarterly transaction reports required under 17j-1(d)(ii) of the Investment Company Act and Rule 204A-1 under the Investment Advisers Act including all required information) which list personal securities transactions for the month must be submitted by Access Persons
no later than the 10
th
day after
the end of each calendar month
. If the 10
th
day falls on a weekend or a holiday, the report is due the business day
immediately preceding
this deadline.
|
• |
Monthly Trade Reports must be submitted using the Monthly Trade Report form to the Chief Compliance Officer. If there are no activities for the month, a report indicating such is still required to be submitted.
|
• |
MAA requires duplicate copies of monthly brokerage account statements to be forwarded to the Chief Compliance Officer. If your broker is unable to directly send duplicate copies, please inform Compliance in writing. When opening or closing brokerage accounts, please notify the Chief Compliance Officer when submitting the monthly trade report.
|
•
|
The Chief Compliance Officer will conduct a review of all Monthly Trade Reports as required under 17j-1(d)(v)(3) and 204A-1. The CIO reviews the Chief Compliance Officer’s Monthly Trade Reports.
|
• |
A List of all Access Persons required to file Monthly Trade Reports with their respective accounts under the reporting requirements is maintained. All Access Persons are notified of the reporting requirements at the time of hire by way of the initial certification with the Code and annually thereafter as Compliance with the Code is re-certified. Certification is in the form of a written acknowledgement that the employee has read and agrees to comply with all aspects of the Code.
|
• |
MAA maintains all copies of Monthly Trade Reports and pertinent documentation to comply with the recordkeeping requirements under 17j-1(f) and 204A-1.
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
11
|
III.3 Post-review |
MAA Compliance will match any broker statements received to pre-clearance requests. Not only for proper preclearance, but also
|
• |
Same day trades
: Transaction occurring on the same day as the purchase or sale of the same security in a managed account.
|
• |
7-day Blackout period
: Transaction up to and including seven calendar days before and after the purchase and/or sale of the same security in a managed account as described in
|
• |
Short-term trading profits
: Purchase/Sale, or vice versa, occurring within 60 days in the same security resulting in net profit. Access Persons are responsible for ensuring that the
|
• |
Other potential conflicts
: Certain transactions may also be deemed in conflict with the Code and will warrant additional review, depending on the facts and circumstances of the transaction.
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
12
|
III.4
Pre-Clearance and
Reporting Requirements
|
The table below indicates pre-clearance and reporting requirements. Requirements for all other security type transactions must be checked with Compliance
|
|
||||
|
Security Type
|
|
Pre-Clearance
|
|
Monthly
Reporting
|
|
|
Equity transactions (1)
|
|
Yes
|
|
Yes
|
|
|
Fixed Inc. transactions
|
|
Yes
|
|
Yes
|
|
|
Mutual Funds advised & sub-advised by MAA Mutual Funds not Advised by MAA
|
|
No
|
|
No
|
|
|
Exchge traded index fd
|
|
Yes
|
|
Yes
|
|
|
US Tsy/Agencies
|
|
Yes
|
|
Yes
|
|
|
Short term/cash equiv.(3)
|
|
No
|
|
No
|
|
|
SPP/DRIPs- auto purch (2)
|
|
No
|
|
No
|
|
|
No Employee 401K- auto purchases (4)
|
|
No
|
|
Yes
|
|
|
All other securities……Consult Compliance Officer
|
|
|
|
III.5
Confidentiality
|
All reports of personal securities transactions, holdings and any other information filed pursuant to this Code will be kept CONFIDENTIAL, provided, however that such information is also subject to review by appropriate MAA personnel (Compliance and/or Senior Management), consultants and legal counsel and may be provided to directors and officers of mutual funds advised or sub-advised by MAA and their legal counsel. Such information may also be provided to the Securities and Exchange Commission (“SEC”) or other government authority when properly requested or under court order.
|
|
|
III.6
Acknowledgment of
Brokerage Accounts
|
All Access Persons are required to submit a list of all brokerage accounts as required by the Code at the time of hire. In addition, Access Persons are responsible for ensuring that any new or closed accounts are communicated to Compliance monthly when submitting the monthly trade report |
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
13
|
III.7
Initial and Annual
Holdings Report
|
All Access Persons are required to report all activity in
brokerage accounts and a statement of holdings (subject to Code
requirements) within 10 days of employment and annually. A broker/custodial statement (no more than 45 days old) will suffice in lieu of a separate initial or annual holdings report. The Access Person is responsible for ensuring that Compliance receives duplicate copies of statements if those are sent directly by the brokers.
|
|
|
|
The Chief Compliance Officer will conduct a review of all initial and annual holdings reports as required under 17j-1(d)(v)(3) and 204A-1. The Chief Investment Officer will conduct a review of the Chief Compliance Officer’s annual holdings reports.
|
|
|
|
A List of all Access Persons required to file initial and annual holdings reports with their respective accounts under the reporting requirements is maintained. All Access Persons are notified of the reporting requirements at the time of hire by way of the initial certification with the Code and annually thereafter as Compliance with the Code is re-certified.
|
|
|
MAA maintains all copies of initial and annual holdings reports and pertinent documentation to comply with the recordkeeping requirements under 17J-1(f) and 204A-1. |
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
14
|
S
ECURITY
T
YPE
|
P
URCHASE
|
S
ALE
|
A.
All Exchange-listed Stocks and Options
and NASDAQ National Market Traded
Equity Securities
|
P
ERMITTED
Subject to one-day blackout during execution of client trades.
Must pre-
clear.
|
P
ERMITTED
, subject to the following:
¾
One-day blackout during execution of client trades.
Must pre-clear.
|
B.
Other Non-Exchange-listed Equity
Securities
|
P
ERMITTED
Subject to pre-clearance requirements.
|
P
ERMITTED
, subject to the following:
¾
Seven-day blackout during execution of client trades. Pre-clearance requirements.
|
C.
Fixed-Income Securities Excluding
Money-Market Instruments
|
P
ERMITTED
Subject to pre-clearance requirements
|
P
ERMITTED
, subject to the following:
¾
Pre-clearance requirements.
|
D.
Mutual Funds Advised and Sub-
Advised by MAA
|
P
ERMITTED
¾
Subject to pre-clearance requirements
|
P
ERMITTED
, subject to the following:
¾
Pre-clearance requirements.
|
E.
Automatic investment programs or
direct stock purchase plans
|
P
ERMITTED
¾
Subject to Code of Ethics reporting requirements
|
P
ERMITTED
¾
Subject to Code of Ethics reporting requirements
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
15
|
IV.2
Short-Term Trading Profits
(60-Day Trading Rule)
|
The purchase and sale, and the short-sale and
purchase of the same security (or equivalent) within 60 calendar days and at a profit is PROHIBITED.
|
• |
This restriction applies without regard to tax lot considerations;
|
• |
Exercised options are not restricted, however, purchases and sales of options occurring within 60 days resulting in profits are PROHIBITED;
|
• |
Exceptions require advance written approval from the firm’s Chief Compliance Officer (or designee).
|
|
Profits from any sale before the 60-day period expires may require disgorgement. Please refer to “Penalties”, section II of this Code, for additional details.
|
|
|
IV.3 Blackout Periods
|
For Exchange-listed stocks and options, NASDAQ National Market traded securities and Fixed-income securities, a one-day firm-wide blackout will apply if the issue is being traded on behalf of a client at the time the pre-clear request is made.
|
All other non-listed issues are subject to a seven-day firm-wide blackout period. | |
Blackout periods apply to both buy and sell transactions |
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
16
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
17
|
IV.6 Independent Research |
MAA research analysts perform independent research of issuers and submit such research to the Investment Policy Committee and Chief Investment Officer.
|
IV.7 Gifts and Hospitality
|
MAA does not allow employees to accept excessive gifts and hospitality. Any gift or hospitality in excess of $250 must be reported to the Chief Compliance Officer.
|
IV.8 Policy Regarding Political Activities by Investment Advisors SEC Rule 206(4)-5 (Pay-to-Play)
|
MAA prohibits its employees to make, or direct or solicit any other person to make, any political contribution or provide anything else of value for the purpose of influencing or inducing the obtaining or retaining of investment advisory services business (“pay-to-play”).
MAA must monitor political activities by its employees. “Employees” are defined as an employee and any member of the employee’s household. Political activities (“Contributions”) are defined as any gift, subscription, loan, advance, or deposit of money or anything of value made for:
|
1.
|
The purpose of influencing any election for federal, state or local office;
|
2.
|
The payment of debt incurred in connection with any such election; or
|
3.
|
Transition or inaugural expenses incurred by the successful candidate for state or local office.
|
|
This includes not only monetary contributions, but also in-kind contributions such as payment for services or use of facilities, personnel or other resources to benefit any federal, state or local candidate campaign, political party committee, or other political committee or political organization exempt from federal income taxes under Section 527 of the Internal Revenue Code (such as the Republican or Democratic Governors Association); or the inaugural committee or transition team of a successful candidate.
|
|
Volunteer services provided to a campaign by employees are also considered Contributions.
|
|
All employees are required to obtain written approval from Matrix’s Chief Compliance Officer and Chief Investment Officer prior to making any Contribution of any value. However, Contributions made to a candidate for federal office where the Candidate is not a state or local official at the time of the Contribution need not be pre-approved.
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
18
|
|
Employees must obtain approval from Matrix’s Chief Compliance Officer and Chief Investment Officer prior to Coordinating or Soliciting Contributions, or engaging in any other political fundraising. Coordinating or Soliciting Contributions, or political fundraising, may even include, for example, merely having one’s name appear in the letterhead or any other portion of a fundraising letter.
|
|
Employees must request approval for such activities in writing by filling out a “Political Contribution Pre- Clearance Form” which can be obtained from MAA’s Chief Compliance Officer.
|
|
MAA will allow employees’ written requests for contributions to any state candidate, local candidate or official, if:
|
|
1. The employee is entitled to vote for such candidate and the Contribution(s) do not exceed $350 per election; or
|
|
2. The employee is not entitled to vote for the candidate and the Contribution(s) do not exceed $150 per election.
|
|
MAA will consider other written requests for contributions on a case by case basis, but precludes Contributions exceeding the above thresholds.
|
|
Contributions made by others (for example, family members residing outside the employee’s household, placement agents, consultants, attorneys, businesses, etc.) at the direction or suggestion of an employee, are considered to be made by that employee for purposes of this Policy. Because of the potential impact on Matrix’s business, this Policy prohibits employees from circumventing this Policy or Rule 206(4)-5 in such manner or any other manner.
|
|
At the end of each calendar year, MAA’s Chief Compliance Officer will distribute an “Annual Political Contributions Certification Form” to all employees. This Form is intended to capture information regarding any Contribution made by each such employee during that calendar year and must be returned within 10 calendar days of receipt.
|
|
Employees must return the forms either (1) acknowledging that no Contributions were made, or (2) disclosing all Contributions made, including Contributions for which the employee received pre- clearance. In order to protect the privacy of employees, the records shall be treated as confidential and may only be reviewed by person(s) with a “need to know” or for purposes of making necessary disclosures to the SEC, if required.
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
19
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
20
|
V.1 Investment Advisers Act of 1940 and Investment Company Act of 1940
|
The SEC considers it a violation of general antifraud provisions of federal securities laws whenever an adviser, such as MAA, engages in fraudulent, deceptive or manipulative conduct. As a fiduciary to client assets, MAA cannot engage in activities which would result in conflicts of interests (for example, “front- running,” scalping, or favoring proprietary accounts over those of the clients’). Employees of MAA are required to obey all of the federal securities laws.
|
V.2
Regulatory Censures
|
The SEC can censure, place limitations on the activities, functions, or operations of, suspend for a period not exceeding twelve months, or revoke the registration of any investment adviser based on a:
|
|
3/4 Failure reasonably to supervise, with a view to prevent violations of the provisions of the federal securities laws, an employee or a supervised person who commits such a violation.
|
|
3/4 However, no supervisor or manager shall be deemed to have failed reasonably to supervise any person, if
|
|
(a) there have been established procedures, and a system for applying such procedures, which would reasonably be expected to prevent and detect, insofar as practicable, any such violation by such other person and
|
|
(b) such supervisor or manager has reasonably discharged the duties and obligations incumbent upon him/her by reason of such procedures and systems without reasonable cause to believe that such procedures and system were not being complied with.
|
V.3 Recordkeeping
|
Rule 204-2 Books and records to be maintained by investment advisers.
|
|
(a)(12)(i) A copy of the investment adviser's code of ethics adopted and implemented pursuant to Rule 204A-1 that is in effect, or at any time within the past five years was in effect;
|
|
(ii) A record of any violation of the code of ethics, and of any action taken as a result of the violation; and
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(iii) A record of all written acknowledgments as required by Rule 204A-1(a)(5) for each person who is currently, or within the past five years was, a supervised person of the investment adviser.
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(13)(i) A record of each report made by an access person as required by 204A-1(b), including any information provided under paragraph (b)(3)(iii) of that section in lieu of such reports;
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Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
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21
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(ii) A record of the names of persons who currently are, or within the past five years were, access persons of the investment adviser; and
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(iii) A record of any decision, and the reasons supporting the decision, to approve the acquisition of securities by access persons under Rule 204A-1(c), for at least five years after the end of the fiscal year in which the approval is granted
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Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
23
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• |
Execute any prohibited purchases and/or sales, directly or indirectly, that are outside those permissible by the Code;
|
•
|
Employ any device, scheme or artifice to defraud Matrix Asset Advisors, Inc., or any company;
|
• |
Engage in any act, practice or course of business which operates or would operate as a fraud or deceit upon Matrix Asset Advisors, Inc. or any company;
|
• |
Make any untrue statement of a material fact, or omit to state a material fact necessary in order to make the statements, in light of the circumstances under which they are made, not misleading;
|
•
|
Engage in any manipulative practice with respect to Matrix Asset Advisors, Inc. or any company;
|
•
|
Trade on inside information;
|
•
|
Trade ahead of or front-run any transactions for MAA managed accounts;
|
•
|
Trade without obtaining the necessary pre-clearance.
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Signature
|
Date | ||
NAME (Print) |
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
24
|
C
ODE
S
ECTION
|
H
OW APPLIED
|
H
OW ADMINISTERED
|
Penalties
|
Penalties will be assessed as
described in the policy if Access Persons violated the applicable sections of the
Code.
|
The Chief Compliance Officer will
apply and report penalties as applicable.
|
Monthly Trade Reports
|
Monthly Trade reports will be
required each month for all personal securities trading as defined in the Code. Monthly Trade Reports are in lieu of quarterly transaction reports required under 17j-1(d)(ii) and
204A-1 and includes all required information.
|
The Chief Compliance Officer will
collect trade reports for Access Persons. Monthly Trade Reports must be received by the Chief
Compliance Officer by the 10
th
day of the month for the previous month’s
trading activity. It is the responsibility of the Access Person to
ensure that the Chief Compliance
Officer receives the Monthly Trade
Report within the 10-day timeframe.
|
Post Review
|
Trades will be reviewed to
assure that all reports were submitted timely and to ascertain any improprieties.
|
The Chief Compliance Officer will
conduct post review of trade reports. The CIO will conduct a post review of the Chief Compliance Officer’s trade reports.
|
Acknowledgement of Brokerage
Accounts
|
Access Persons are required to
notify the Chief Compliance
Officer if they have opened or closed a brokerage account when submitting a monthly trade report.
|
The Chief Compliance Officer will
collect and review monthly trade reports to determine if any brokerage
accounts have been opened or closed
for Access Persons.
|
Initial and Annual Holdings
Report
|
Initial reports will be required
at hire and annual holdings at each year-end for all Access Persons. Broker statements
may be used to satisfy these
requirements.
|
The Chief Compliance Officer will
collect and review initial and annual holdings reports for Access Persons. Initial and annual holdings reports
must be submitted to the Chief
Compliance Officer within 10 days of hire and following each year-end. Initial and annual holdings reports must contain current holdings information (no more than 45 days
old ).
|
Matrix Asset Advisors, Inc. Code of Ethics 3.13.17
|
24
|
Insider Trading Restrictions
|
Insider trading restrictions will
apply as described in the Code.
|
Trade reviews described above seek
to identify any cases of insider trading.
|
Initial and Annual Political
Contribution Reports
|
Initial and Annual Political
Contribution Reports will be required.
|
The Chief Compliance Officer will
collect and review of all Initial and Annual Political Contributions Reports to ensure that all activity is conducted in compliance with the Code.
|
Nature of Interest
|
Broker, Dealer (or
|
|||||
Name of Security/
|
Number of
|
Security
|
(Direct Ownership,
|
Bank acting as
|
||
Ticker or Cusip#
|
Shares/Par Amount
|
Type
|
Price
|
Principal Amount
|
Spouse, Control, Etc.)
|
Broker) Involved
|
|
|
|
|
|
|
Received By:
|
Reviewed By
|
Comments:
|
||||
Title:
|
Title:
|
|
||||
Date:
|
Date:
|
|
Nature of Interest
|
Broker, Dealer (or
|
|||||
Name of Security/
|
Number of
|
Security
|
(Direct Ownership,
|
Bank acting as
|
||
Ticker or Cusip#
|
Shares/Par Amount
|
Type
|
Price
|
Principal Amount
|
Spouse, Control, Etc.)
|
Broker) Involved
|
|
|
|
|
Received By:
|
Reviewed By
|
Comments:
|
||||
Title:
|
Title:
|
|
||||
Date:
|
Date:
|
DATE
|
NAME OF
SECURITY
|
# OF SHRS,
PAR
AMOUNT,
ETC.
|
APPROX.
PRICE
|
TICKER
SYMBOL
OR
CUSIP #
|
PRINCIPAL
AMOUNT
|
PURCHASE
(P)
SALE
(S)
|
DIRECT
OWNER-
SHIP (D)
SPOUSE (S)
CONTROL
(C)
|
APPROVED
or
DENIED
|
|
||||||||
|
||||||||
|
||||||||
|
Date of Trade
|
Buy or Sell
|
Security/Ticker
|
No. of Shares
|
Interest
|
Maturity
|
Price
|
Broker
|
Commission
|
Other Pertinent
|
or Cusip
|
and Principal Amt.
|
Rate
|
Date
|
Information
|
|||||
1
|
|||||||||
2
|
|||||||||
3
|
|||||||||
4
|
|||||||||
5
|
|||||||||
6
|
|||||||||
7
|
|||||||||
8
|
Elected
|
State/
|
Contribution
|
Contribution
|
||
Date
|
Name of Official
|
Non-Elected
|
Municipality
|
Value
|
Format (i.e. cash, in-kind etc.)
|
|
|
|
|
DATE
|
NAME OF STATE/
LOCAL GOVERNMENT
OFFICIAL
|
ELECTED/
NON-
ELECTED
|
STATE/ LOCAL
MUNICIPALITY
|
INTENDED CONTRIBUTION
VALUE
|
INTENDED
CONTRIBUTION
FORMAT
(i.e. CASH, IN-KIND)
|
APPROVED/
DENIED
|
|
||||||
|
||||||
|
||||||
|