Personal Trading and Proxy Tests
Here’s a few more tests, as suggested by Pickard and Djinis partner Mari-Anne Pisarri at last week’s ICAA/IA Week conference:
After each quarter, determine which access persons did not file their quarterly transaction reports within 30 days of the end of the calendar quarter. "If you spend a lot of time tracking [access persons] down," said Pisarri, "maybe you want to change your procedure" and require access persons to automatically submit duplicate confirms and brokerage account statements to the adviser.
Sample some portion of access persons’ trades. Did the access person buy something on the firm’s restricted list? Were there any IPOs or limited offering securities? Were they precleared?
- At the end of the proxy voting season, sample a number of proxies to determine whether the firm missed any votes and whether votes were cast in accordance with applicable proxy policies. For fund advisers, she added, "maybe the time to do it is after you file your Form N-PX."