This panel will take a fresh look at personnel-related conflicts of interests, and specifically those concerning personal trading, private securities transactions, and outside business activities. Panelists will propose suggestions based on experience acquired over the years through case studies, SEC notices, and exam results in addition to reviewing considerations for dual registrants and the differing standards of care between broker-dealers and investment advisers.
• Analyze the firm’s written statement of business conduct and fiduciary obligations
• Review and rationalize the declaring and reporting requirements for broker-dealers and 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, best practices for dealing with repeat violators, and the evolution of the firm’s control environment for these conflicts