Code of Ethics

Click here to open up a Word document that a peer contributes. It is the firm's policies and procedure for gifts and entertainment under the ...

Mario Hernandez, director of operations at Gemmer Asset Management in Walnut Creek, Calif., shares his firm's gifts and entertainment reporting form.

What SEC examiners focus on can shift like the sands, depending on what's hot and the type of firm being queried. We've come up with ...

This hedge fund manager was charged with cherry-picking. The SEC noted the firm lacks relevant compliance P&Ps or a code of ethics that would have ...

This adviser withdrew its registration after a slew of compliance violations, including lacking adequate compliance P&Ps and failing to maintain various books and records such ...

This compliance policies and procedures manual comes courtesy of Albert Gutierrez, CCO at Atlas Capital Advisors in San Francisco, who refers you to his firm’s ...

This pair failed to investigate numerous serious red flags indicating misconduct by a colleague, according to the SEC.

Some firms make the mistake of cramming so much into their code of ethics that it can't realistically be policed - setting themselves up for ...

This is a sample risk assessment that covers nearly 50 potential conflicts and compliance topics.

The SEC provides broad outlines of how you should implement your code of ethics. You're free to go beyond the basics, but if you do, ...