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Personal Trading

A policy for a fundamental compliance duty
CCOs should know which consultants are working at their firm and whether they have access to trading information
The CCO of a Massachusetts-based investment adviser won’t have to pay any further penalties after serving a criminal sentence for bilking his firm’s clients out ...
If your firm pays a radio station to run an ad, you better tune in.   That’s one lesson from the SEC enforcement action against ...
This matter involves violations of the Advisers Act and certain rules thereunder by CPI, a registered investment adviser, that: (i) distributed hundreds of radio advertisements ...
The credentials heralded by the hedge fund adviser principal were certainly impressive—an MBA in finance from Dartmouth, a prior portfolio manager with Bear Stearns, a ...
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 ethics.
Multiple compliance backstops were in place at hedge fund adviser Brahman Capital Corp. to safeguard confidential information. Despite the firm’s written P&Ps, code of ethics, ...
These proceedings arise out of the failure of WSC, a registered broker-dealer, to establish, maintain, and enforce written policies and procedures reasonably designed, taking into ...
The Advisers Act expects that access persons will report their securities transactions and that you’ll review them. A former SEC staffer found there’s a price ...
The SEC's complaint alleges that David R. Humphrey, who worked at the SEC from 1998 to 2014, concealed his personal trading from the SEC's ethics ...
The SEC Jan. 25 charged a Massachusetts-registered investment adviser and its managing partner, CCO and sole employee Michael Breton with cherry-picking client trades. The case ...
FGIMC did not establish or maintain written policies or procedures for identifying outside consultants who – based on their functional roles and whether they had ...
You’re well aware that Advisers Act rule 204A-1 (codes of ethics) requires you to review access persons’ transactions. You may not know that SEC examiners ...
Hardly a week goes by now without the SEC bringing another enforcement action against a private fund adviser for issues tied to fees and expenses ...
A peer shares her firm's code of ethics and personal trading policy.
This release from June 2015 recommends compliance staff dig deeper when determining that an access person's trading doesn't need review because it qualifies for an ...
You may wish to do more before deciding an access person’s personal trades don’t need to be reviewed because they supposedly fall under the code ...
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 ...
(a) Definitions. For purposes of this section: (1) Access person means: (i) Any Advisory Person of a Fund or of a Fund's investment adviser. If ...
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