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September 16, 2021

Two Persistent Compliance Challenges: Insider Trading and Advisory Contracts



Jeff Blumberg and Jim Lundy are instructing on “Two Persistent Compliance Challenges: Insider Trading and Advisory Contracts” for the Investment Adviser Association’s (IAA) Investment Adviser Certified Compliance Professional® (IACCP®) Program. Jim and Jeff’s training covers:

  • Insider trading, including introduction to Rule 204A-1 — Investment Advisers Code of Ethics
    • Insider trading law and regulation
    • Misuse of Material, Nonpublic Information (MNPI)
    • Primary elements including materiality, nonpublic information, violation of duty, tipper/tippee liability and enforcement, personal benefit, and scienter or “wrongful intent”
    • Rule 10b5-1 (1934 Act): Trading “on the basis of” MNPI
    • SEC enforcement actions
    • Material nonpublic information at the firm
    • Prevention of misuse of nonpublic information
    • Section 204A policies, procedures, enforcement and training
    • Rule 204A-1 code of ethics, including who is covered, elements, holdings reports, transactions reports, reportable securities, reporting exceptions, additional requirements and enforcement actions
    • Failure to supervise, including pitfalls, vigilance and enforcement actions
  • Section 205 — Investment Advisory Contracts
    • Definition of investment advisory contracts
    • Prohibition
    • Performance fee exemption
    • Clauses including hedge clauses and ERISA clauses

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