The ongoing insider trading investigations and civil and criminal enforcement actions involving Wall Street professionals is a reminder of the importance of an investment adviser having effective policies and procedures to detect and prevent the misuse of material nonpublic information. This mission-critical topic will be a focal point of the course.
Section 204A requires investment advisers to establish, maintain and enforce written policies and procedures reasonably designed to prevent the misuse of material nonpublic information by the firm or its associated persons. The course will include a discussion on the development of the law of insider trading, recent insider trading cases involving securities professionals, and elements of an effective insider trading policy and code of ethics.
The course will also cover the Advisers Act Section 205, which governs the SEC requirements for advisory contracts, including an opportunity to explore industry standards in this area.