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Personal Trading

CCOs should know which consultants are working at their firm and whether they have access to trading information
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.
A policy for a fundamental compliance duty
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 ...
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 ...
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