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Gifts and Entertainment (38)
Your search for Gifts and Entertainment returned 38 results.
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1/21/2018 | Content area: Investment Adviser
A peer shares a one-page primer aimed at helping staff understand their responsibilities under the firm's personal trading section of its code of ethi...
2/20/2017 | Content area: Investment Adviser
A peer shares a portion of the firm's code of ethics. These are sample policies and procedures for gifts and entertainment as well as pay-to-play.
2/09/2017 | Content area: Investment Adviser
Your compliance role can be so much easier when management supports you – and ever more painful when a firm’s owner overrules you.   A new SEC settlem...
2/08/2017 | Content area: Investment Adviser
Between at least 2011 and October 2014, JSA disseminated marketing materials containing representations that JSA had “never, not once, taken even so m...
3/17/2016 | Content area: Investment Adviser
It can be challenging when you report to multiple regulators to keep their gifts and entertainment thresholds straight. The Department of Labor’s $250...
8/28/2015 | Content area: Investment Adviser
From about February 2008 to about March 2012, Bennett provided an employee of a proxy solicitation firm with nonpublic information about ISS clients i...
8/10/2015 | Content area: Investment Adviser
GPIM breached its fiduciary duty by failing to disclose that one of its senior executives approached an advisory client and received a $50 million loa...
6/18/2015 | Content area: Investment Adviser
In an attempt to temper the tempest stirred by last February’s SEC Division of Investment Management guidance on registered fund gifts and entertainme...
6/04/2015 | Content area: Investment Adviser
IA Watch has learned that some industry groups are asking the SEC to come out with additional guidance about fund advisers and gifts and entertainment...
4/02/2015 | Content area: Investment Adviser
Nearly all advisers don’t place a limit on the number of personal trades staff can make annually. The typical holding period – for firms that have one...
2/24/2015 | Content area: Investment Adviser
If you’re a compliance officer for a fund adviser, chances are you’re well aware a gifts and entertainment policy should be in your code of ethics or ...
2/24/2015 | Content area: Investment Adviser
This guidance from the Division of Investment Management encourages fund compliance personnel to maintain P&Ps about gifts and entertainment. The Inve...
1/02/2015 | Content area: Investment Adviser
Whatever the Financial Stability Oversight Council’s next move is toward regulating asset managers, it will be aided by comments from the industry, sa...
10/30/2014 | Content area: Investment Adviser | Broker-Dealer
An easy out for many compliance staff given the duty to train firm employees on gifts and entertainment rules is to adopt the lowest regulatory thresh...
10/30/2014 | Content area: Investment Adviser | Private Fund
Only a few months after the SEC charged an investment adviser with falsely claiming compliance with the Global Investment Performance Standards (IA Wa...
11/26/2013 | Content area: Investment Adviser
Click here to open a Word file that is an example of a peer's annual certification form for staff to attest to having read the firm's code of ethics.
11/04/2013 | Content area: Investment Adviser
This is an example of a code of ethics from a dually-registered firm.
3/18/2013 | Content area: Investment Adviser
When does a head trader turn into the belle of the ball? When he's new.The line of brokers coming to see the new head trader named by NFJ Investment G...
2/06/2013 | Content area: Investment Adviser
Click here to open up a Word document that a peer contributes. It is the firm's policies and procedure for gifts and entertainment under the code of e...
2/06/2013 | Content area: Investment Adviser
Mario Hernandez, director of operations at Gemmer Asset Management in Walnut Creek, Calif., shares his firm's gifts and entertainment reporting form.


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