IA Compliance: The Full 360° View East 
March 7-8, 2019 | Washington, D.C.

UPCOMING WEBINARS

Conquering Current Compliance Challenges
Dec. 12, 2018 | 2:00 - 2:30 PM EST
 
RECORDED WEBINARS

Conquering Current Compliance Challenges
Recorded: November 14, 2018 
 
HANDBOOKS
  Includes: 9 Best Practices, 3 Proposed Disclosure Mockups
and a 60-minute Audio Webinar

The Adviser's Guide to SEC Advertising and Marketing Rules
Includes: 23 Best Practices, 5 Peer-tested tools and 15 No Action Letters

The SEC Examinations Priorities Handbook
Includes: 28 Best Practices, 20 Document Request Letters and 6 OCIE Risk Alerts

Cybersecurity Strategies to Ensure SEC Compliance, 2nd Edition
Includes: 24 Best Practices, 16 Tools, 4 Risk Alerts and IM Guidance

 
CODE OF ETHICS OVERVIEW
While many Advisers Act rules are principles-based – meaning it’s up to the registered entity to put policies in place to reasonably comply with the intent of the rule – there exists a clear requirement for all registered advisers to establish, maintain and enforce a written code of ethics.
 
The relevant Advisers Act rule is rule 204A-1 (investment adviser codes of ethics).
 
You code should fit your firm, although there are certain provisions that must, at a minimum, be addressed. For example, your COEs must speak to a standard of “business conduct” for your “supervised persons.” It must contain provisions requiring your supervised persons to comply with applicable securities laws, to report their personal securities transactions and alert compliance to code violations. It is this rule that holds compliance “or other persons” to review staff personal trading reports, provide the code to employees and to receive back a written acknowledgement of that receipt.

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