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Portfolio
Holdings
Disclosure Policy
PEARL
MUTUAL FUNDS
PEARL MANAGEMENT COMPANY
Portfolio Holdings
Disclosure Policy
Updated May 1, 2006
A. Introduction.
1.
Pearl Mutual Funds (“PMF”) and Pearl Management Company (“PMC”) believe
frequent and uniform fair disclosure to the public of information on the
portfolio holdings of Pearl Total Return Fund and Pearl Aggressive Growth
Fund (the “Funds”) is in the best interests of the Funds’ shareholders and
potential investors.
2.
However, this information is confidential and proprietary until uniform fair
disclosure to the public is made. Selective disclosure of such information
could have adverse ramifications for the Funds’ shareholders.
3.
In order to ensure frequent and uniform fair disclosure to the public while
preventing any inappropriate selective disclosure of portfolio information,
PMC and PMF’s Board of Trustees have adopted and implemented this portfolio
holdings disclosure policy (the “Policy”).
4.
PMC administers this Policy on behalf of PMF and the Funds.
5.
Each Officer and each employee of PMF or PMC is required to familiarize
himself or herself with this Policy.
6.
A summary description of this policy is available
in the Statement of Additional Information and on the Funds’ Website:
www.pearlfunds.com.
B. Uniform Public Disclosure Policy.
1.
PMC and the Funds uniformly disclose each Fund’s month-end
portfolio holdings to the public once a month,
reporting the most recent month-end portfolio. This is done no later than
the fifth day after month-end. This portfolio information is
available at
www.pearlfunds.com and upon
request.
2. In
addition, any Executive Officer of a Fund may decide to update the portfolio
information on the Website at any time when this additional public
disclosure is believed to be advisable.
3.
Only the most recent portfolio information report is posted on the Website,
and it remains on the Website until replaced by the next portfolio
information report.
4. The information posted on the Website includes the name
of each portfolio security and its percentage of the Fund’s total assets.
The scope of the information
provided may change from time to time without prior notice.
C. Restrictions on Prior Disclosure.
1.
PMC and the Funds will not disclose the portfolio information prior to
public disclosure on the Website. PMC and the Funds will not enter into any
agreement to disclose Fund portfolio holdings information in exchange for
any form of consideration. These restrictions apply to all categories of
persons, including, without limitation,
individual investors, institutional investors, intermediaries, service
providers, and rating and ranking organizations.
2.
Any Executive Officer of a Fund may disclose to Trustees of the Funds
portfolio information prior to public disclosure on the Website, in
connection with preparation for Board meetings and other instances
appropriate for the operation of the Funds. Any such disclosure is made
only if it is in the shareholders’ interest.
3. All personnel of PMC and of the
Funds who have access to the Funds’ portfolio information prior to public
disclosure are subject to the Code of Ethics of PMF and PMC.
D. Disclosure Implementation.
1.
After the Funds’ month-end (or other applicable) NAV statements have been
approved by the Controller and Chief Financial Officer of PMC, the
statements are given to the President and Portfolio Management
Associate for their review.
2.
The Portfolio Management Associate and the outside Internet
Technology provider are responsible for updating the Website. The
Funds’ Website is then checked by the President and the Chief Financial
Officer to ensure that the Website version matches the confirmed NAV
statements.
3.
The Funds’ portfolio holdings are also
disclosed to the public through their filings with the SEC. The Funds file
their portfolio holdings with the SEC for each quarter on Form N-CSR (with
respect to each annual period and semi-annual period) and Form N-Q (with
respect to the first and third quarters of the year). Shareholders may
obtain the Funds’ Forms N-CSR and N-Q filings on the SEC’s Website at
www.sec.gov. In addition, the
Funds’ Forms N-CSR and N-Q filings may be reviewed and copied at the SEC’s
public reference room in Washington, D.C. Anyone may call the SEC at
1-800-SEC-0330 for information about the SEC’s Website or the operation of
the public reference room.
4. After portfolio information has already been made
public through Website disclosure or in an SEC filing, it may thereafter be
disclosed to anyone and may be used in marketing literature and in
communications to shareholders and others.
E. Policy
Oversight.
PMC reports at least annually to the PMF Board of Trustees on the
implementation of this Policy. The PMF Board of Trustees also annually
receives and evaluates a report on compliance with the Code of Ethics of PMF
and PMC.
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