Trading Practices, Portfolio Compliance and Related Enforcement Cases
As a fiduciary, an investment adviser has many obligations to the client including developing, implementing and testing policies, procedures and disclosures to ensure proper trading practices. Compliance, legal and trading experts will offer an overview of the trading process and appropriate best practices, and provide “hands-on” compliance solutions for the following mission-critical areas: fiduciary duty and client investment objectives/restrictions, aggregation, allocation, personal and proprietary trading, principal and agency cross transactions, side-by-side management, effective supervisory systems, and special considerations for hedge funds.
This session will focus on the critical risk area of portfolio compliance. Managing a client’s portfolio within relevant limitations and objectives is one of the most important fiduciary responsibilities of an investment adviser. Investment advisers are responsible for knowing their clients’ investment policies, guidelines and mandates, as well as any other applicable investment restrictions, and for managing their clients’ accounts strictly in accordance with such guidelines and restrictions. The SEC views consistency of portfolio management decisions with clients’ mandates as a primary internal control process.
After attending this course, attendees should be able to:
- Manage portfolio trading compliance, including client restrictions, allocation and aggregation procedures and testing
- Assess and implement an effective compliance trading system so that your firm can operate in a manner consistent with industry best practices
- Examine the intersection of compliance, trading and operations to help detect and eliminate questionable trading activity that could lead to compliance violations and SEC fines
- Recognize complex trading arrangements and pinpoint compliance red flags
- Evaluate approaches to portfolio compliance monitoring
- Extract lessons to be learned from relevant SEC enforcement cases.
For Whom: Chief Compliance Officers, Compliance Staff at all levels, Trading personnel, Persons involved with monitoring client portfolios, Management and Legal counsel.
Suggested Skill Level: Intermediate
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 to become familiar with the structure and terms.
Advance Preparation: None