Hedge Funds Wrestle with Employee Personal Account Trading Conflicts

Forbes – Trading ahead of client accounts. Insider trading. Breach of fiduciary duty.

These were just some of the concerns that the SEC had when it adopted the requirement for investment advisers to establish policies to monitor employee personal trading in 2004.  While seemingly straightforward, in the decade since the adoption of SEC Rule 204A-1, investment advisers still struggle to find the right balance of policy, procedure and cost in meeting the Rule’s requirements.

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