Personal Trading

Multiple compliance backstops were in place at hedge fund adviser Brahman Capital Corp. to safeguard confidential information. Despite the firm’s written P&Ps, code of ethics, ...

These proceedings arise out of the failure of WSC, a registered broker-dealer, to establish, maintain, and enforce written policies and procedures reasonably designed, taking into ...

The Advisers Act expects that access persons will report their securities transactions and that you’ll review them. A former SEC staffer found there’s a price ...

The SEC's complaint alleges that David R. Humphrey, who worked at the SEC from 1998 to 2014, concealed his personal trading from the SEC's ethics ...

The SEC Jan. 25 charged a Massachusetts-registered investment adviser and its managing partner, CCO and sole employee Michael Breton with cherry-picking client trades. The case ...

FGIMC did not establish or maintain written policies or procedures for identifying outside consultants who – based on their functional roles and whether they had ...

Hardly a week goes by now without the SEC bringing another enforcement action against a private fund adviser for issues tied to fees and expenses ...

You may wish to do more before deciding an access person’s personal trades don’t need to be reviewed because they supposedly fall under the code ...

This release from June 2015 recommends compliance staff dig deeper when determining that an access person's trading doesn't need review because it qualifies for an ...

Nearly all advisers don’t place a limit on the number of personal trades staff can make annually. The typical holding period – for firms that ...