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Investment Adviser Codes of Ethics: The Rule Plus Implications of Gifts and Whistleblowers
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 session 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 session 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. Implications of gifts policies and whistleblowers will be examined to highlight the unique characteristics of these potential conflicts of interests.
After attending this session, 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 gifts and whistleblower policies.
For Whom: Designed to increase the professional competence of investment adviser professionals with legal, compliance and management responsibilities
Suggested Skill Level: Basic
Instructional Method: Group Internet-Based and Group-Live
Pre-requisites 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.
Advance Preparation: None