Presentation

Investment Adviser Codes of Ethics: The Rule, Plus Pay to Play, Gifts and Whistleblowers

August 28, 2013

Morgan Lewis associate John J. O'Brien presented, "Investment Adviser Codes of Ethics: The Rule, Plus Pay to Play, Gifts and Whistleblowers," for the National Regulatory Services Webinar.

Objectives:

  • Explain and implement the requirements of Securities and Exchange Commission (SEC) Rule 204A-1: Investment Adviser Codes of Ethics
  • Implement processes to effectively monitor and control personal securities trading by adviser personnel to avoid potential conflicts and possible ethics violations
  • Draft required Form ADV ethics disclosure and maintain required recordkeeping
  • Administer and tailor a code of ethics for your firm to address potential risk areas such as SEC Pay-to-Play requirements, gifts and whistleblower policies