A course with a title like "Code of Ethics" sounds pretty amorphous. But these codes are not. They are specifically required by SEC rule and impose specific requirements for advisers. This course will explain them and how to implement them. The sections include:

• Introduction to the idea of a required Code of Ethics for each investment adviser and one focus on regulating the flow of material, nonpublic information about issuers that may be within the firm.

• Access Persons

  • Who are they?

  • What kinds of reports do they have to file?

• Reporting Exceptions -- How can reports for access persons be avoided, or greatly simplified?

• Adviser Review – Now what do you do with those reports once you get them?

• Procedures for Reviewing Personal Trading

  • When should access persons trade securities?

  • Where should they trade?

  • Is some trading out of bounds entirely?

• Insider Trading Protections – Investment advisers of various levels of complexity might need different sorts of procedures to prevent or discourage insider trading. What do you need?

Get ready for the ride of your life.