IA Information Walls and Codes of Ethics


Investment Advisers are required by IAA Rule 204A-1 to institute procedures to prevent the misuse of material nonpublic information and to adopt a "Code of Ethics" that governs, at a minimum, the following matters: (i) the fiduciary standard of conduct to which an adviser is subject; (ii) the adviser's obligation to comply with the federal securities laws; (iii) the obligations of the adviser's "access persons" as to reporting of personal securities transactions and holdings; as well as the related obligation to seek pre-approval of certain transaction; (iv) the obligation of supervised persons to report violation of the Code appropriately; (v) the obligations of. each supervised person to acknowledge his obligations under the Code; and (vi) the obligation of the adviser to keep records of various matters relating to the enforcement of the Code. See also the Focus Page on IAs and RICs: General Supervisory Obligations.



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