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.
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
October 12, 2020
On September 28, 2020, the U.S. Securities and Exchange Commission (“SEC”) filed a complaint against an investment adviser representative located in Nebraska for allegedly cherry picking profitable trades for his personal investment account, while disproportionately assigning unprofitable trades to investment advisory client accounts. During the alleged scheme, which ran from January 2017 to March 2018, the SEC asserts that the investment adviser representative earned a 4.4% return on his personal investment account while his disfavored clients earned a negative 12.56% return. Click here to read the SEC’s complaint.