Commitment to Compliance
September 17 | Philadelphia
Conquering Current Compliance Challenges
Sept. 26, 2018 | 2:00 - 2:30 PM EST
 
RECORDED WEBINARS

Conquering Current Compliance Challenges
Recorded: August 15, 2018 
  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

 
PROPRIETARY TRADING OVERVIEW
Proprietary Trading constitutes one of the areas for which the SEC has suggested investment advisers maintain compliance P&Ps. This is how the SEC has put it: P&Ps covering “proprietary trading of the adviser and personal trading activities of supervised persons.”
 
The definition of the term has evolved with time but basically refers to trades that the adviser does, well, for itself. You can see easily how these could create conflicts of interest and enforcement risks.
 
Another definition prescribes the term for banks that sponsor a hedge fund that trades on behalf of the bank. The so-called Volcker rule targets such behavior.
 
However, for our purposes here, the term’s meaning is the former one.
 
Personal trading reviews also fall under this topic but we’ve relegated it to our Trading page.
 
There are several Advisers Act sections and rules that are implicated by proprietary trading. For instance, Advisers Act section 204A insists on P&Ps reasonably designed to prevent the misuse of material nonpublic information.

Advisers Act section 206 (prohibited transactions by investment advisers) requires an adviser to obtain written client consent prior to engaging in a principal trade – buying or selling a security from the adviser’s own account.

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