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This Sample Code of Ethics includes provisions required by the Code of Ethics rule, drafting notes, and other topics that advisers may include in a Code of Ethics or other policies and procedures, including Gifts and Entertainment, Charitable Contributions, Political Contributions, Outside Business Activities. The document also includes recordkeeping requirements and sample certifications.
May 10, 2024
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March 09, 2023
This outline discusses the definition of material nonpublic information (MNPI) and related regulatory issues, and requirements of the SEC’s Whistleblower rules.
March 09, 2023
This presentation discusses the requirements of the code of ethics rule, firm approaches, issues related to the code, and resources.
March 09, 2023
Exams Risk Alert: Investment Adviser MNPI Compliance Issues
This SEC Exams Risk Alert discusses deficiencies cited in examinations related to the Code of Ethics rule, including policies and procedures for alternative data, value-add investors, expert networks, and other requirements of the rule.
April 26, 2022
SEC Risk Alert Focuses on MNPI and Code of Ethics Compliance Issues
The SEC has issued a risk alert on MNPI and Codes of Ethics.
April 28, 2022
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