Who is considered an access person?
An access person is a supervised person who has access to nonpublic information regarding clients’ purchase or sale of securities, is involved in making securities recommendations to clients or who has access to such recommendations that are nonpublic.
What are considered reportable securities?
Reportable Securities means the same as the term used in Rule 204A-1, and includes any common stock, preferred stock, closed-end investment company, Reportable Fund, debt securities, any put, call, straddle, option or privilege on any security or on any group or index of securities, security future2, any interest or …
What is a reportable holding?
Reportable Security means any Security, except that it does not include: (i) transactions and holdings in direct obligations of the Government of the United States; (ii) bankers’ acceptances, bank certificates of deposit, commercial paper and other high quality short-term debt instruments, including repurchase …
Is a 401k a reportable security?
401(k) plans of an Access Person’s prior employer(s) or 401(k) plans of Immediate Family Members must be disclosed if such accounts have the capacity to invest in Affiliated Open-end Mutual Funds and/or other Reportable Securities.
What is rule 204-2 of the Investment Advisers Act?
The Rule 204-2 of the Investment Advisers Act of 1940 is one of the most important rules issued by the Securities and Exchange Commission (SEC) as it specifies the various categories of books and records that investment advisers must retain and produce upon request during SEC examination.
Who is responsible for maintaining records under Rule 204-2?
Irrespective of the medium used, any adviser that sends or receives written communications covered under Rule 204-2 is responsible for maintaining those records.
What are the requirements of Section 203 of the Act?
(a) Every investment adviser registered or required to be registered under section 203 of the Act ( 15 U.S.C. 80b-3) shall make and keep true, accurate and current the following books and records relating to its investment advisory business;
What is a section 13 (13) (I) of Rule 204A-1 (B)?
(13) (i) A record of each report made by an access person as required by Rule 204A-1 (b), including any information provided under paragraph (b) (3) (iii) of that section in lieu of such reports; (ii) A record of the names of persons who are currently, or within the past five years were, access persons of the investment adviser; and