Insider Trading, Contracts and New ADV Delivery Requirements
October 24, 2013
1:00 PM – 3:00 PM ET
The ongoing surge of insider trading investigations and civil and criminal enforcement actions involving Wall Street professionals is a reminder of the importance of an investment adviser having effective policies and procedures to detect and prevent the misuse of material nonpublic information. This mission-critical topic will be a focal point of the course.
Section 204A requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed to prevent the misuse of material nonpublic information by the firm or its associated persons. The panel of experts will discuss the development of the law of insider trading, recent insider trading cases involving securities professionals, and elements of an effective insider trading policy and code of ethics.
This session will also cover the Advisers Act Rule 204-3, which governs client delivery of new Form ADV Part 2.
The session will address SEC requirements for advisory contracts and provide an opportunity to explore industry standards in this area.
After attending this course, attendees should be able to:
• Identify the elements of an effective insider trading policy to help detect and prevent the misuse of material nonpublic information
• Explain and implement the requirements of SEC Rule 204A-1: Investment Adviser Codes of Ethics
• Employ processes under your code of ethics to effectively prevent and detect insider trading and monitor personal securities trading by adviser personnel
• Determine what, how and when to deliver the new Form ADV Part 2, using the amendments of Rule 204-3 (Delivery of brochures and brochure supplements)
• Increase awareness of industry standards for client agreements
• Use practical tips to help improve your firm's advisory agreement
For whom: Chief Compliance Officers, Ethics Officers, Compliance Staff at all levels, Management, Legal counsel and Auditors
Suggested Skill Level: Intermediate
Instructional Method: Group Internet-Based and Group Live
Prerequisites for participation:
No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940, especially Sections 204A and 205, and Rules 204-3 and 204A-1, to become familiar with the structure and terms.
Advance Preparation: None
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