IA- Investment Adviser Code of Ethics (COE) (Rule 204A-1)

The Investment Adviser Code of Ethics serves as an important part of an investment adviser’s overall compliance program.  Rule 204A-1 of the Advisers Act requires registered investment advisers to adopt codes of ethics and requires an adviser's code of ethics to set forth standards of conduct and require compliance with federal securities laws. Codes of ethics must also address personal trading: they must require advisers' personnel to report their personal securities holdings and transactions, including those in affiliated mutual funds, and must require personnel to obtain pre-approval of certain investments.  The Code includes eight separate sections and a signed acknowledgement section. Members also downloaded Restricted Securities List, Investment Adviser Rep Annual Compliance Certification or Insider Trading Statement of Understanding.

Version/Update: V.2/September 27, 2018

Total Page Count: 7

Source/Author(s): Connexien