Advisers must be sure that their annual compliance review includes the firm’s code of ethics. Under the Adviser’s Act, all SEC registered advisers are required to adopt and enforce a written code of ethics, which is applicable to all of the adviser’s supervised persons.
The rule specifically requires an adviser’s code of ethics to set forth standards of ethical conduct and require compliance with federal securities laws. It must be reviewed annually to assess the effectiveness of its implementation.
When reviewing your firm’s code of ethics, it is important to verify that as a minimum it contains the following:
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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