Before
Firm X has adopted and implemented a Code of Ethics to maintain the interest of our clients, in accordance with its fiduciary duties under the Investment Advisers Act of 1940. Firm X’s policy allows employees to maintain personal securities accounts provided any personal investing by an employee in any accounts in which the employee has a beneficial interest, including any accounts for any immediate family or household members, is consistent with Firm X’s fiduciary duty to its clients and consistent with regulatory requirements.
Since Firm X is a small investment adviser, each employee of Firm X is considered an access person and must identify any personal investment accounts and report all reportable transactions and investment activity on a quarterly basis to the firm’s Compliance Officer.
Each access person shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No person of Firm X shall prefer his or her own interest to that of the advisory client.
Before, with commentary
Firm X has adopted and implemented a Code of Ethics to maintain the interest of our clients, in accordance with its fiduciary duties under the Investment Advisers Act of 1940. Firm X’s policy allows employees to maintain personal securities accounts provided any personal investing by an employee in any accounts in which the employee has a beneficial interest, including any accounts for any immediate family or household members, is consistent with Firm X’s fiduciary duty to its clients and consistent with regulatory requirements. [Decide whether to use first person or third person and be consistent.]
Since Firm X is a small investment adviser, each employee of Firm X is considered an access person [this should be explained] and must identify any personal investment accounts and report all reportable transactions [this too] and investment activity on a quarterly basis to the firm’s [are you “Firm X,” or “the firm”?] Compliance Officer.
Each access person shall not [this is a double negative] buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No person of Firm X shall prefer his or her own interest to that of the advisory client. [This paragraph looks like it was lifted directly from the code of ethics.]
After
Firm X has implemented a Code of Ethics to protect the interests of our clients and to comply with our fiduciary duties under the Investment Advisers Act of 1940. The Code of Ethics allows employees to maintain personal securities accounts. However, any investing by an employee for the employee’s own account, or for the account of an immediate family or household member, must be consistent with regulatory requirements and with Firm X’s fiduciary duty to our clients. In general, no Firm X employee may prefer his or her own interest to the interests of our advisory clients.
No Firm X employee may trade for a personal (or family) account if the trading decision is based on information the employee obtained by working at Firm X unless the information also is available to the investing public on reasonable inquiry. All employees must identify their personal investment accounts and report all transactions and investment activity on a quarterly basis to Firm X’s Compliance Officer.
