When establishing a compliance program, an investment adviser is required to review and monitor the personal securities transactions by “access persons” in order to prevent inappropriate trading. In order to supervise personal securities transactions, the first question is determining which individuals are access persons. The U.S. Securities and Exchange Commission (“SEC”) defines an “access person” [...]
Category Archives: Compliance Training
One-Day Audits Being Conducted on Newly Registered SEC Investment Advisers
The U.S. Securities and Exchange Commission (SEC) has been examining certain recently registered investment advisers by conducting limited scope, one-day examinations. According to the SEC’s cover letter sent in advance of these audits, “the purpose of these examinations is to assess and discuss important risk areas presented be the registered investment advisers’ operations and the [...]





