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: PST
SEC Internal Compliance Program for Personal Securities Trading of Its Employees Is a Reminder to RIAs About Supervising PST of Its Access Persons
In a May 22, 2009 U.S. Securities and Exchange Commission (“SEC”) press release, Mary Schapiro, SEC Chairman, outlined new steps being taken to strengthen the SEC’s internal compliance program to guard against inappropriate personal securities trading by SEC employees. Previous internal rules for SEC employees prohibited, among other things, short selling, carrying securities on margin, [...]





