HomeWebcastSEC Rule 204A-1: Personal Securities Trading, Ethics and Compliance
SEC Rule 204A-1: Ethics and Compliance CLE CLE

SEC Rule 204A-1: Personal Securities Trading, Ethics and Compliance

Live Webcast Date: Friday, February 26, 2016 from 10:00 am to 12:00 pm (ET)
Ethics/Professional Responsibility CLE & CPERecording

SEC Rule 204A-1: Ethics and Compliance CLE

Join us for this Knowledge Group SEC Rule 204A-1: Ethics and Compliance CLE Webinar. In June 2015 the Securities and Exchange Commission (SEC) issued guidance on the Reporting Exception of SEC Rule 204A-1. The rule states that a registered investment adviser must require the 'access persons' – employees with access to private securities transactions information or those recommend securities to clients – to report all their personal securities holdings and transactions.

The guidance addresses accounts where the 'access person' is: a grantor or beneficiary of a trust managed by a third party trustee or who gives discretionary authority to a third party manager.

It is important that compliance officials carefully review accounts from the outset to determine whether it qualifies initially and remains qualified for the Reporting Exception. An adviser can no longer rely on the 'access person' to confirm lack of influence or control on securities transactions for an account.

The Knowledge Group has assembled a panel of key thought leaders and practitioners to provide a two-hour Webcast to review and discuss the recent Reporting Exception of SEC Rule 204A-1. Speakers will discuss the SEC’s Code of Ethics Guidance on Personal Securities Reporting and suggest what investment advisers should consider to ensure compliance with the new rule.

Some of the major topics that will be covered in this course are:

  • Rule 204A-1: An Overview
  • Personal Securities Reporting: Updates
  • Scopes and Limitations of Regulation
  • Underlying Effects for Investment Advisers
  • Possible Risks and Pitfalls
  • Potential Adoption and Implementation Issues
  • Regulatory Developments
  • Best Compliance Practices

Who Should Attend

  • Investment Advisers
  • Financial Advisers
  • Advisory Firms
  • Broker-dealers
  • Investors
  • Financial Statement Preparers
  • Shareholders
  • Multinational Companies
  • Other Related/Interested Professionals and Organizations

Faculty

SEC Rule 204A-1: Ethics and Compliance CLE
Frederick C. Leech
Partner
Leech Tishman
SEC Rule 204A-1: Ethics and Compliance CLE
Genna Garver
Of Counsel
Dorsey & Whitney
SEC Rule 204A-1: Ethics and Compliance CLE
Asher Ailey
Chief Compliance Officer
SouthernSun Asset Management

Click Here to Read Additional Material

SEC Rule 204A-1: Ethics and Compliance CLE

SEGMENT 1:
Frederick C. Leech, Partner
Leech Tishman
  • Rule 204A-1 – Investment Adviser Codes of Ethics
  • Tight Cluster of Enforcement Actions Centering On Market Timing and Late Trading -- Political Tug of War Between Attorneys General and SEC
  • Essentials of the Rule – “establish, maintain and enforce a written code of ethics that, at a minimum, includes …”
  • Definitions of Access Person and Reportable Fund
  • Reporting Requirements – Holdings Reports; Contents
  • Definition of Reportable Securities
  • Reporting Requirements – Holdings Reports; Timing
  • Reporting Requirements – Transactions Reports; Contents and Timing
  • Reporting Requirements – Exceptions from Reporting Requirements

SEGMENT 2:
Genna Garver, Of Counsel
Dorsey & Whitney
  • Developing personal securities trading policies and procedures
    • who to include as Access Persons
    • bells and whistles for pre-clearance -- blackout periods
    • length of time approvals are good for
    • restricted/watch lists, etc.

SEGMENT 3:
Asher Ailey, Chief Compliance Officer
SouthernSun Asset Management
  • Practical elements of implementation
    • how to make pre-clearance determinations
    • how to deal with violations (including disclosure on DDQs and RFPs) and whether to use technology to monitor compliance
    • to elaborate on violation tracking internally, documentation and violation reporting internally
    • activity, instruments and account types that can be in and out of scope of a personal securities program and the factors that should be involved in making these determinations
  • Addressing issuing exceptions to the policy and the different considerations associated with approving an exception

SEC Rule 204A-1: Ethics and Compliance CLE

SEC Rule 204A-1: Ethics and Compliance CLE

Frederick C. LeechPartnerLeech Tishman

Fred Leech is a partner in Leech Tishman’s Pittsburgh office and is Chair of the firm’s Corporate Practice Group, where he has a wide-ranging legal practice advising business clients on regulatory matters, corporate governance and acquisition transactions. Fred is also a member of Leech Tishman’s Management Committee.

Fred serves as outside general counsel to a number of operating company clients, principally in the manufacturing and media industries. In this role, in addition to managing his own legal projects, Fred oversees the delivery of a wide range of services in areas such as intellectual property, employment, tax, litigation, environmental law and benefits. Fred also has significant experience representing investment advisers in regulatory matters and strategic transactions.

Prior to joining Leech Tishman, Fred spent 35 years at Reed Smith, where he focused on corporate, finance and investment management legal issues.

SEC Rule 204A-1: Ethics and Compliance CLE

Genna GarverOf CounselDorsey & Whitney

Genna takes pride in the close personal attention she provides when advising investment management clients in connection with federal and state securities laws, private fund formation and securities offerings. She has extensive experience representing financial institutions in transactional and regulatory matters. She focuses on representing investment advisers, hedge funds and other private investment funds implementing various investment strategies.

Genna advises clients on: formation and offering matters for both domestic and offshore funds; SEC and state investment adviser, broker-dealer and private fund regulation; Investment Advisers Act compliance programs; and mock audits and regulatory examinations and investigations. She also counsels banking and private fund clients on all aspects of the Volcker Rule and related matters.

Genna is Of Counsel in Dorsey’s Corporate Group and chairs the Investment Regulation practice.

SEC Rule 204A-1: Ethics and Compliance CLE

Asher AileyChief Compliance OfficerSouthernSun Asset Management

Mr. Ailey joined SouthernSun in 2014 and was appointed as Chief Compliance Officer in March 2015. He is responsible for overseeing and managing the firm’s compliance program. Additionally, Mr. Ailey provides strategic support to the firm on all legal matters.  Prior to joining SouthernSun, Mr. Ailey was Head of Compliance (Americas) for Partners Group and also previously served as Chief Compliance Officer of Alphadyne Asset Management LLC. He received his J.D. from Rutgers University School of Law in Newark, New Jersey and received his B.A. in Political Science from Temple University in Philadelphia, PA.

SEC Rule 204A-1: Ethics and Compliance CLE

Course Level:
   Intermediate

Advance Preparation:
   Print and review course materials

Method Of Presentation:
   On-demand Webcast

Prerequisite:
   NONE

Course Code:
   145159

NASBA Field of Study:
   Business Law

NY Category of CLE Credit:
   Ethics & Professionalism

Total Credits:
    2.0 CLE

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About the Knowledge Group

The Knowledge Group

The Knowledge Group has been a leading global provider of Continuing Education (CLE, CPE) for over 13 Years. We produce over 450 LIVE webcasts annually and have a catalog of over 4,000 on-demand courses.

About the Knowledge Group

The Knowledge Group

The Knowledge Group has been a leading global provider of Continuing Education (CLE, CPE) for over 13 Years. We produce over 450 LIVE webcasts annually and have a catalog of over 4,000 on-demand courses.

Leech Tishman Fuscaldo & Lampl is a full-service law firm dedicated to assisting individuals, businesses, and institutions. Leech Tishman offers legal services in alternative dispute resolution, bankruptcy & creditors’ rights, construction, corporate, employee benefits, employment, energy, environmental, safety & toxic torts, estates & trusts, government relations, immigration, insurance coverage & corporate risk mitigation, intellectual property, internal investigations, international legal matters, litigation, real estate, and taxation. Headquartered in Pittsburgh, PA, Leech Tishman also has offices in Chicago, Los Angeles, New York and Wilmington, DE. For more information call 412.261.1600 or visit us at www.leechtishman.com. - See more at: https://leechtishman.com/publications/supreme-court-to-revisit-decades-old-union-fee-issue/#sthash.VR4j5UAs.dpuf

Website: https://leechtishman.com/

Clients have relied on Dorsey since 1912 as a valued business partner. With locations across the United States and in Canada, Europe and the Asia-Pacific region, Dorsey provides an integrated, proactive approach to its clients' legal and business needs. Dorsey represents a number of the world's most successful companies from a wide range of industries, including leaders in the banking, energy, food and agribusiness, health care, mining and natural resources, and public-private project development sectors, as well as major non-profit and government entities.

Website: https://www.dorsey.com/

"SouthernSun Asset Management, founded in 1989 in Memphis, TN, is an investment adviser that manages approximately $4.5 billion in assets across three strategies: U.S. SMID Cap, U.S. Small Cap, and Global Equity (as of 12/31/15). Using a bottom-up, fundamentally-based investment approach, the firm seeks to invest in attractively-valued companies exhibiting niche dominance, financial flexibility, and management adaptability."

Website: https://www.southernsunam.com/

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