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 … Continued
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 … Continued
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 … Continued
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, … Continued
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 … Continued
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 … Continued
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 … Continued
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 … Continued
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 … Continued