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Personal Trading

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Heed the lessons of the SEC’s latest off-channel communications enforcement action against an adviser and you may well sidestep a similar fate
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Here's an example of a personal trading policy and procedure
Examiners may want to see additional procedures to be comfortable that the firm could adequately conduct its reviews given this situation
A peer shares her firm's code of ethics and personal trading policy
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This is an example of a certification form you can ask a subadviser to use quarterly to attest that it's abiding by your code of ...
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This is an example of a peer's annual certification form for staff to attest to having read the firm's code of ethics
Use this form to document due diligence of non-recommended or non-approved holdings
A peer shares the firm's annual disclosure given to access persons for them to report their securities holdings
Compliance can generate commission reports as well as the average cents per share the firm pays. Finance or operations could show a list of vendors ...
The ruckus stirred by the Robinhood fiasco earlier this year also exposes a risk for compliance officers. Could your access persons evade your personal trading ...

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