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Are there any specific personal securities reporting requirements of a SEC registered investment adviser related to the SEC Rule 204A-1?

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A SEC registered investment adviser must require all access persons to submit to the chief compliance officer or other designated person, a report of all current securities holdings and transaction reports for reportable securities in which the access person has, or acquires, any direct or indirect beneficial ownership. Holdings reports must be submitted no later than 10 days after the person becomes an access person and at least annually thereafter. All information reported must be current as of a date no more than 45 days prior to the date reporting is required.

A registered investment adviser must also require access persons to submit to its chief compliance officer or other designated person, quarterly securities transactions reports no later than 30 days after the end of the calendar quarter.

A SEC registered investment adviser’s codes of ethics must require access persons to obtain approval before they directly or indirectly acquire beneficial ownership in any security in an initial public offering (“IPO”) or in a limited offering (“private placement”).

In addition to receiving these reports, the SEC’s rule requires that the investment adviser’s code of ethics provide that the chief compliance officer or other designated party of the investment adviser review these personal securities transaction reports. Reviewing these PST reports will allow the investment adviser as well as any securities regulator to detect any improper trades or trading patterns by access persons.

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