Personal Trading

Personal Trading: Stay on Top of Challenges, Be Ready for New Ones

Advisory firm chief compliance officers should avoid falling into the trap of thinking that compliance with personal trading requirements is low-hanging fruit. While it may be as simple as reviewing periodic reports for some employees, compliance in this area can be more complex and challenging.

New OCIE Risk Alert Focuses on Principal Trading and Agency Cross Trading

The SECs Office of Compliance Inspections and Examinations, in a September 4 Risk Alert, lets advisers know the most frequent principal trading and agency cross-transaction compliance issues that examiners observed – and therefore what firms can expect examiners to make a point of looking at during future visits. Specifically, the Risk Alert focuses on compliance […]

Personal Trading: Take Steps to Detect and Prevent

Chief compliance officers need to monitor personal trading. It can be difficult to do, but it can be done.

Ferret Out Personal Trading in Your Firm Before the SEC Does

Proactive steps you take now to uncover improper personal trading may save your firm a lot of grief later on.

Portfolio Manager Faces SEC Action for Deceiving Chief Compliance Officer

The SEC on August 27, in a first of its kind action, sanctioned an advisory firms former assistant portfolio manager under Rule 38a-1(c) under the Investment Company Act for forging documents and misleading the firms chief compliance officer to hide his failure to report personal trades. The portfolio managers actions, which resulted in a settlement […]

Guidance For Your Insider Trading Program

[Correction: The initial version of this story incorrectly attributed Sutherland Law Firm partner Brian Rubin’s comments to ACA Compliance Group partner Barry Schwartz. The corrected version appears below.]Insider trading is the new Ponzi scheme.At least, thats how it appears to be shaping up after the SECs numerous recent announcements of complaints and enforcement actions involving […]

CCOs Should Review Areas of Top Exam Deficiencies

The top five areas of deficiencies most commonly found during adviser exams “are very, very consistent from year to year,” according to OCIE associate director Gene Gohlke. And since those areas are so well-known, CCOs should do something about them. Speaking at the recent “SEC Speaks” conference in Washington, D.C., Gohlke said that if he […]

CCO Fired After Raising Front-Running Concerns

This is one heck of a story.Joseph Sullivan used to be the COO and CCO of Peconic Partners, a New York hedge fund manager that currently has about $1 billion under management. If his name rings a bell, its because youve heard him speak at the SECs CCOutreach National Seminar. Back in 2006, Sullivan appeared […]

Personal Trading: Reviewing Your Code of Ethics (Part 2 of 2)

(Continued from the October 20 issue.) Here are a few additional items to consider as you review your code of ethics: Has your firms preclearance policy held up in light of the past two months? Per the Advisers Act code of ethics rule, your code must require access persons to obtain preapproval before directly or […]

Richards: What Compliance Officers Should Focus On Now

According to OCIE director Lori Richards, the “most important” thing for compliance officers at advisory firms to do right now is to remind their firms employees about their fiduciary obligations to clients. Beyond that, she suggested a number of specific areas that compliance officers should “pay particular attention to.” SEC examiners, she noted, will be […]

Audio Interviews

How to Read an SEC Enforcement Action

Stern Tannenbaum law firm partner Aegis Frumento on how to get the most from reading an SEC administrative order or court complaint.

Most Important Supreme Court Decisions for Advisers and Funds

Find out the high court decisions from recent years that are likely to affect how advisers and investment companies work from Debevoise partner Robert Kaplan. 

Top 10 Cybersecurity Steps to Take Now

Sutherland law firm partner Brian Rubin shares the most urgent cybersecurity steps for investment advisers.

Top Marketing Problems … and Solutions

Get solutions for the top marketing challenges that advisers face from ACA Compliance Group managing director Kimberly Daly

Watch Out for 5 Cybersecurity Myths

ACA Aponix Director Pascal Busnel on the most common cybersecurity myths that may cause firms to spend resources where they may not be needed.

The Hidden Costs of Non-Compliance

Proskauer law firm partner and former SEC Division of Investment Management deputy director Robert Plaze on why the costs of non-compliance go way beyond an SEC penalty.

CCO Liability: How to Protect Yourself

Find out from Blue Edge Capital CCO Margaret Fretz what chief compliance officers may be liable for and best practices to make sure you are protected.

Ethics or Compliance: Making the Choice

Find out the difference an ethics, rather than a compliance, perspective makes at an advisory firm from former Ethics and Compliance Officer Association COO Timothy Mazur.