You Created a Code of Ethics, But Did You Disclose It?

Is your firm's new Code of Ethics described in your ADV Part II? Does your ADV Part II allow clients to request a copy of the Code of Ethics? This is an item that some investment advisors have overlooked. The recently effective SEC Rule 204A-1 requires all SEC registered firms to include a summary of the Code of Ethics in the Form ADV Part II, and, upon request, to provide a complete copy of the code of ethics to advisory clients.

Labels: Code of Ethics