An anonymous compliance hotline within your investment adviser suddenly receives complaints about a market-beating portfolio manager. Your in-house compliance and legal team investigate and learn this portfolio manager may have been the beneficiary of some particularly timely information in advance of certain corporate announcements, leading to his highly successful year trading in the fund he manages. He denies doing anything wrong and accuses the (still anonymous) whistleblower of being jealous of his success. As images from episodes of “Billions” scroll through your mind, you try to decide what to do. Do you self-report? Do you tell the Securities and Exchange Commission (SEC)?

Originally published in The Investment Lawyer - October 2017.