Investment Adviser Codes of Ethics: The Rule Plus Pay to Play, Gifts and Whistleblowers
February 12, 2013
1:00 PM – 3:00 PM ET
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 will focus on identifying the requirements that must be covered in an adviser’s code of ethics and tailoring a code to meet your firm’s business operations and risks. This course will also provide guidance on implementing firm-wide ethics policies and procedures that help remind adviser personnel of their obligations to clients and avoid conflicts of interest. Gifts policies and political contributions and whistleblowers rules will be examined to highlight the unique characteristics of these potential conflicts of interests.
After attending this course, attendees should be able to:
- Explain and implement the requirements of SEC Rule 204A-1: Investment Adviser Codes of Ethics
- Implement processes to effectively monitor and control personal securities trading by adviser personnel to avoid potential conflicts and possible ethics violations
- Draft required Form ADV ethics disclosure and maintain required recordkeeping
- Administer and tailor a code of ethics for your firm to address potential risk areas such as SEC political contributions requirements, gifts and whistleblower policies
For whom: Chief Compliance Officers, Ethics Officers, Compliance Staff at all levels, Management, Legal Counsel and Auditors
Suggested Skill Level: Basic to Intermediate
Instructional Method: Group – Internet
Prerequisites 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.
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