Investment Adviser Codes of Ethics – Requirements and Best Practices
Monitoring Personal Securities Trading and Gifts and Entertainment
March 9, 2010
1:00 PM – 3:00 PM EST
Presented by:
Valerie Baruch-Assistant General Counsel, IAA
John Walsh- Associate Director and Chief Counsel, OCIE
Description: Ethics is not an option; it’s a requirement. Since the adoption of the SEC Rule on Codes of Ethics, every registered investment adviser firm must adopt codes of ethics that establish standards of conduct and address conflicts that arise from personal trading issues. Many state advisers have also adopted a Code of Ethics either in response to state mandates or as an industry best practice. Instruction and guidance for this course focus on identifying the required components of standard codes of ethics and learning how to draft plans for implementing firm-wide ethics policies and procedures that both help remind adviser personnel of their obligations to clients and avoid conflicts of interest.
Learning Objectives:
- Understand and implement the requirements of SEC Rule 204A-1: Investment Adviser Codes of Ethics
- Explain processes for monitoring and controlling personal securities trading by adviser personnel to avoid potential conflicts and possible ethics violations
- Review requirements for ADV disclosure and recordkeeping
- Comprehend the processes for administering and tailoring a code of ethics for your firm
For Whom: Chief Compliance Officers, Ethics Officers, Compliance Staff at all levels, Management, Legal counsel, Auditors
Suggested Skill Level: Basic to Intermediate
Instructional Method: Group - Internet Based
Pre-requisites for participation: No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940, especially Rule 204A-1, to become familiar with the structure and terms.
Continuing Education Credits: Recommended CPE Credit: 2
