Compliance Solutions for Investment Advisers

Category Archives: Code of Ethics

The 4 Most Typical Code of Ethics Violations

As stated in the recent SEC Risk Alert, four typical code of ethics violations identified during examinations of investment advisers include:

Alert – Insider Trading

The purpose of this Compliance Alert is to familiarize you with key insider trading concepts and issues. What is Insider Trading? The buying or selling of a security, in breach of a fiduciary duty or other relationship of trust and confidence, while in possession of material, nonpublic information about the security. Insider trading is the

Quarterly Transaction Reports

All Access Persons must submit personal securities transaction reports no later than thirty (30) days after the end of each calendar quarter. The information contained in the Transactions Report must cover all transactions made by the Access Person during that quarter. An Access Person may provide monthly account statements and duplicate trade confirmations in lieu

Trained in Compliance = Liable for Insider Trading?

Mathew Martoma attended hedge fund SAC Capital Advisors LP’s annual compliance training sessions two years in a row, an officer with the firm said, testimony that could bolster the insider-trading case against the former portfolio manager, according to the Wall Street Journal. The testimony by John Casey, an SAC compliance officer, could buttress the government’s contention

SEC Examiner Faces Criminal Charges

From the Financial Times: A veteran examiner with the Securities and Exchange Commission faces criminal charges for filing false government ethics forms over his ownership of bank stocks in violation of agency rules. Steven Gilchrist, a SEC examiner since 1996, was arrested on Tuesday morning on three counts of making false statements to the government.

Insider Trading Can get Expensive

The SEC obtained a $13.9 million penalty against former Goldman Sachs board member Rajat K. Gupta for illegally tipping corporate secrets to former hedge fund manager Raj Rajaratnam.  Gupta also is permanently barred from serving as an officer or director of a public company.The SEC previously obtained a record $92.8 million penalty against Rajaratnam for prior insider

SEC Charges Adviser with Front Running

The SEC has charged a Dallas-based registered investment adviser’s primary equity trader with insider trading and trading ahead of large block trades for the adviser’s clients through one of his wife’s brokerage accounts. The trader failed to report his wife’s accounts and one of his accounts, and holdings and transactions in these accounts to the

Adviser Standards of Conduct

The SEC has recently published a request for data and other information to assist the agency in considering whether to make new rules about the standards of conduct and regulatory obligations for broker-dealers and investment advisers when they provide personalized investment advice about securities to retail customers. “Studies have shown that few investors realize that

You Ain’t Going to Get Away With it

Attorney, Wall Street Trader, and Middleman Settle SEC Charges in $32 Million Insider Trading Case The Securities and Exchange Commission announced a settlement in a $32 million insider trading case against a corporate attorney and a Wall Street trader. The SEC alleged that the insider trading occurred in advance of at least 11 merger and

SEC Releases Risk Alert on Unauthorized Trading

From the SEC’s Risk Alert: Washington, D.C., Feb. 27, 2012 – The Securities and Exchange Commission today released an alert to help firms prevent and detect unauthorized trading in brokerage and advisory accounts. The Risk Alert issued by the agency’s Office of Compliance Inspections and Examinations (OCIE) notes that although broker-dealers and investment advisers are