The Insider Trading Statement of Understanding serves as an important part of an investment adviser’s overall compliance program in accordance with SEC Rule 206(4)-7 and/or similar state requirements. The Insider Trading and Securities Fraud Enforcement Act of 1988 requires to firms to establish, maintain, and enforce procedures that are reasonably designed to prevent the misuse of non-public information and associated persons are strictly prohibited from trading on any information that could be considered material, non-public information. The Statement of Understanding includes the policies related to insider trading and a signed acknowledgement section.  Members also downloaded Investment Adviser Code of Ethics or Investment Adviser Rep Annual Compliance Certification.

Version/Update: V.2/September 27, 2018

Total Page Count: 3

Source/Author(s): Connexien