An investment adviser firm is required to review and monitor the personal securities transactions (“PST”) by “access persons” in order to prevent inappropriate trading.
Tag Archives: PST
Review Q3 Personal Securities Transactions
February 23, 2025
An investment adviser firm is required to review and monitor the personal securities transactions (“PST”) by “access persons” in order to prevent inappropriate trading.
Review Q2 Personal Securities Transactions
February 23, 2025
An investment adviser firm is required to review and monitor the personal securities transactions (“PST”) by “access persons” in order to prevent inappropriate trading.
Review Q1 Personal Securities Transactions
February 23, 2025
An investment adviser firm is required to review and monitor the personal securities transactions (“PST”) by “access persons” in order to prevent inappropriate trading.
SEC Brings Enforcement Action Against Investment Adviser Firms for Failing to Supervise for Cherry-Picking
October 14, 2024
Regulatory Alert
In a recent cease-and-desist order, the U.S. Securities and Exchange Commission (“SEC”) censured and fined two investment adviser firms for allegedly failing to supervise “cherry-picking” practices by two of its investment adviser representatives (IARs).
The U.S. Attorney’s Office (District of Connecticut) announced that it entered into a plea agreement with an owner/investment adviser representative of an investment adviser firm based in Connecticut. This CT investment adviser representative waived his right to be indicted and pled guilty to defrauding clients of $2.7 million through a cherry-picking scheme. Last month, the U.S. Securities and Exchange Commission (“SEC”) also issued a cease-and-desist order against this investment adviser representative and firm. This blog post will review the cherry-picking allegations and offer several best practices for a chief compliance officer (“CCO”) to detect such activity within his or her own investment adviser firm.
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.
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