Mike Xifaras , Kurt Decko, Of Counsel, K & L Gates
Description:
SEC advisers and investment companies are required to have a Code of Ethics and many state advisers have adopted a Code either in response to state mandates or as an industry best practice. Code of Ethics and personal trading are always an area of high regulatory scrutiny and frequently generate examination deficiencies. This session will review requirements under SEC Rule 204A-1, best practices, practical tips and Code-related topics, such as gift policies and monitoring, rumors, pay to play and employees’ outside activities. This session will guide you in tailoring your firm’s Code of Ethics to be effective, manageable and deficiency free. Form ADV and books and records requirements pertaining to this topic will also be covered.
For whom:
Chief Compliance Officers and other compliance professionals, legal counsel, internal auditors & managers
Learning Objectives:
Examine standards of business conduct that codes must address.
Understand the rule requirements for personal securities transactions procedures, reporting and reviews.
Discuss industry best practices and practical tips for compliance.
Examine requirements for ADV disclosure and record keeping.
Understand the processes for administering and tailoring a code of ethics for a firm’s needs.
Pre-requisites for participation:
No prerequisites are required. However, attendees can benefit by reviewing the Investment Advisers Act of 1940, esp. Rule 204A-1 (Code of Ethics) & 204-2 (12) Books & Records) and the Investment Company Act of 1940, esp. Rule 17j-1 (Code of Ethics) to become familiar with the requirements and definitions of the relevant rules