8g. IA LAB - Best Practices for Drafting & Revising Codes of Ethics and Conduct (Advanced - CLOSED)
This panel will examine Rule 204A-1’s minimum requirements for a Code of Ethics and provisions that a firm may wish to adopt as part of its compliance program under Rule 206(4)-7. Specific attention will be paid to conflicts of interest arising from personal trading, private securities transactions, outside business activities, gifts and entertainment, and political contributions. Panelists will propose suggestions based on experience acquired over the years through case studies, SEC notices, and exam results. This session is closed to regulators and members of the press.
The following learning objectives will be met using case studies, examples, group discussions, and other hands-on activities:
● Analyze the firm’s written statement of business conduct and fiduciary obligations.
● Review and rationalize the declaring and reporting requirements for investment advisers and the need for automation and transparency.
● Discuss some of the pitfalls that companies have experienced, and the lessons learned from them, including close calls for OBAs, such as volunteerism and charitable giving and the competing priorities around personal trading controls.
● Discuss different approaches used to manage these conflicts, as well as best practices for dealing with repeat violators, and the evolution of the firm’s control environment for these conflicts, and provisions that may not be advisable.
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