06/30/2010
Take some ideas from one of your peer's gifts and entertainment policies.
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05/25/2010
Click here to open a Word file that is an example of a certification form you can ask a subadviser to use quarterly to attest that it's abiding by your code of ethics..
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04/30/2010
Click here for a certification form from one of your peers. This is entitled Employee Conflict of Interest Disclosure and Ethics Certification Form. A form like this is an excellent way to document your annual efforts to uncover outside business activity by firm principals and to track potential con ...
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3/29/2010
The vendor had a special gift for the head trader: a primo ticket to the big college football tussle pitting Texas against Oklahoma. The CCO had to decide whether the trader could accept the gift or drop it like a slippery fumble."We denied the individual," recalls David Hunt, deputy CCO at NFJ Inve ...
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03/23/2010
Click here to read a copy of a peer's gifts and entertainment policy.
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01/11/2010
Here is another copy of a 407 letter template. This one comes courtesy of Peter Mafteiu of Sound Compliance Services in Gig Harbor, Wash. Here is another 407 letter, which compliance officers can use to request duplicates of account statements and transactions from brokerages used by staff personnel ...
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1/11/2010
It's standard practice for compliance officers to monitor staff personal trading by examining an employee's brokerage statements and trade confirmations. Compliance officers request these documents from brokers by sending a "407 letter." One of your peers has kindly shared a Word file template of su ...
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01/06/2010
Click here to open a Word file, which is a template you can use for a so-called 407 letter. Firms use such letters to persuade brokers to send duplicate accounts and trade confirmations of employee trading to bolster efforts by compliance staff to monitor personal trading. This template was created ...
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11/05/2009
This is an example of an annual questionnaire and certification, courtesy of Steven Felsenthal, general counsel and CCO at The Millburn Corporation in Greenwich, Conn. The questionnaire can support your code of ethics and help you uncover issues, such as employee relationships, that may warrant further inquiry to avoid possible insider trading.
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10/5/2009
You could have the best personal trading policy around but if it doesn't give someone the responsibility to review the CCO's trading it contains a glaring mistake."OCIE's going to pick that up in a second," said Dan Kahl, branch chief in the SEC's Division of Investment Management, in speaking at IA ...
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