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The Investment Adviser Disclosure of Accounts at Broker-Dealers and Other Financial Institutions is a useful template to satisfy the disclosure and notification requirements under an adviser’s code of ethics. Under these requirements, an adviser's "access persons" must periodically report their personal securities transactions and holdings to the adviser's chief compliance officer or other designated persons and the adviser must review those reports to identify improper trades or patterns of trading by access persons.
Version/Update: V.1/March 2, 2018
Total Page Count: 2
Source/Author(s): Connexien
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