Sec Employee Personal Trading Compliance Requirements
One of the main issues impacting compliance officers today is the difficulty of monitoring the personal trading activities of employees in accordance with best practice and industry regulations. Adherence torules such as SEC Rule 17j-1 and Rule 204A-1 and adoption of the best practices recommended by the SEC can be very time consuming and distracting for any compliance department.
The main requirements of an Investment Adviser under rule 204A-1 and Rule 17j-1 are:
- Adoption of Code of Ethics.
- Process to monitor employee personal trading
- Reporting by all access persons of all holdings within ten days of becoming an access person and at least once within each twelve month period thereafter.
- Submission of transaction reports by access persons no later than 30 days after the end of each calendar quarter. The report must cover, at a minimum, all personal trading transactions during the quarter.
- Trade Pre-Clearance approval of certain investments. Access persons must obtain approval before they directly or indirectly acquire beneficial ownership in any security in an initial public offering or in a limited offering.
The SEC when amending rule 17j-1 in 2004 also recommended that Investment Advisers adopt the following in their code of ethics.
- Prior written approval before access persons can place a personal securities transaction ("pre-clearance").
- Maintenance of Restricted lists e.g. Lists of issuers of securities that the Registered Investment Adviser firm is analyzing or recommending for client transactions, and prohibitions on personal trading in securities of those issuers.
- Maintenance of "restricted lists" of issuers about which the Registered Investment Adviser has insider information, and prohibitions on any trading (personal or for clients) in securities of those issuers.
- Blackout periods when client securities trades are being placed or recommendations are being made and when access persons are not permitted to place personal securities transactions.
- Reminders that investment opportunities must be offered first to clients before the Registered Investment adviser or its employees may act on them, and procedures to implement this principle.
- Prohibitions or restrictions on short-swing trading and market timing.
- Requirements for employees placing personal trades to trade only through certain brokers, or limitations on the number of brokerage accounts permitted.
- Requirements to provide the adviser with duplicate trade confirmations and account statements.
- Procedures for assigning new securities analyses to employees whose personal holdings do not present apparent conflicts of interest.
There are many Personal Trading or Compliance Management systems which allow firms to automate this employee personal trading process. These systems vary from systems which capture employee brokerage statements to systems which allow you to provide end to end employee personal trading surveillance.
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