Fund managers have long known that SEC-registered investment advisers are required to establish, maintain and enforce a written Code of Ethics for their firms. Rule 204A-1 under The Investment Advisers Act of 1940 (“Advisers Act”) lays out seemingly straightforward requirements for this document, identifying “at a minimum” certain business and employee obligations of conduct and policies. What could possibly go wrong? Plenty.

Although the Code of Ethics (“COE”) generally aligns well with firms’ additional compliance and business policies, it has several important distinctions, the most significant of which is that compliance is absolute. The COE is not a “best efforts” proposition: Get it wrong and face the potential of civil penalties, injunctions, disgorgement, or even criminal penalties. All have been seen in related Enforcement actions.

On July 22, please join AIMA and ACA Group for a webinar to revisit the Code of Ethics Rule, taking a back-to-basics look at what all SEC-registered investment advisers should consider in crafting and complying with this core component of SEC registration. During this session, we will take a fresh look at the COE, exploring some of the more nuanced aspects that are anything but innocuous, discussing potential pitfalls and identifying best practices.

Whether you are a new registrant working on an initial draft or a seasoned practitioner who may be overdue for a COE refresh, we hope you will join us. As always, attendee questions are welcome and encouraged.

Panelists:

Enrique Carlos Alvarez, Managing Director, ACA Group

Suzan Rose, Senior Adviser, Government and Regulatory Affairs, AIMA

Sponsored by: