In general, an investment adviser firm’s code of ethics requires each access person within the firm to submit annually to the firm’s chief compliance officer (“CCO”) or other designee a report of the access person’s current personal securities holdings.
Tag Archives: Insider Trading
Request Supervised Persons Complete Annual Attestations
December 16, 2022
As compliance best practice and/or possibly a requirement under an investment adviser firm’s compliance manual, each supervised person of the firm should submit the following items to the firm’s chief compliance officer (“CCO”) or designee on an annual basis:
Investment Advisers Are Required to Maintain and Enforce P&P to Prevent Trading on Inside Information
February 15, 2021
Challenges Facing a CCO Supervising Against Insider Trading
On June 23, 2020, the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) released a Risk Alert about its assessment of the compliance practices of SEC registered investment advisers that manage private equity funds or hedge funds (“private fund advisers”). In its Risk Alert, the SEC noted that over 36% of SEC registered investment advisers manage private funds, which represent a significant area of investment for pensions, charities, endowments, and others. Click here to read the SEC’s Risk Alert for Private Funds.
