Personal Trading

Spruce up your firm's personal trading P&Ps by gaining ideas from this sample P&P

Access Persons must certify annually to, among other things, their personal securities holdings, their securities accounts and transactions and compliance with various firm policies

Cycle exams found issues with enforcing a supervisory system reasonably designed to review the securities transactions in outside brokerage accounts

Gain ideas for your personal trading P&Ps by eyeing this one

Heed the lessons of the SEC’s latest off-channel communications enforcement action against an adviser and you may well sidestep a similar fate

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

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 ...

This is an example of a peer's annual certification form for staff to attest to having read the firm's code of ethics