Advisers Act
Proposed Rule 204A-1 |
Investment Company Act
Rule 17j-1 |
- Code of Ethics
Required for each investment adviser registered with the Commission. |
- Code of Ethics
Required for each investment adviser of a registered investment company.
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- Standards of Conduct
Required element of code of ethics.
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- Standards of Conduct
Not required.
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- Compliance with Laws
Required element of code of ethics.
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- Compliance with Laws
Not required in code of ethics.
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- Limited Access to Material Nonpublic Information
Required element of code of ethics.
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- Limited Access to Material Nonpublic Information
Not required.
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- Internal Reporting of Code Violations
Required element of code of ethics.
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- Internal Reporting of Code Violations
Not required in code of ethics.
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- Employee Acknowledgment
Employee must receive copy of code of ethics and acknowledge in writing.
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- Employee Acknowledgment
Not required.
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- Reportable Securities exclude:
- Direct obligations of the U.S. government;
- Money market instruments;
- Shares issued by unaffiliated open-end funds and money market funds.
- Personal Securities Reports
- Initial and Annual Holdings Reports
- Quarterly Transaction Reports
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- Personal Securities Trading Reports
Required by rule.
- Reporting Personnel
"Access Persons" any directors, officers, general partners of the adviser.
"Advisory persons" employees and certain control persons (and their employees) who obtain information regarding fund securities transactions or recommendations.
For advisers not primarily in the business of advising funds or advisory clients, access persons only include directors, officers, general partners, or advisory persons, who make or who obtain information concerning, recommendations made to fund.
- Reportable Securities exclude:
- Direct obligations of the U.S. government;
- Money market instruments;
- Shares issued by open-end funds.
- Personal Securities Reports
- Initial and Annual Holdings Reports
- Quarterly Transaction and New Account Reports
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- Pre-Approval of Trades
Required for IPO and Limited Offering.
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- Pre-Approval of Trades
Required for IPO and Limited Offering.
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- Recordkeeping
- Copies of codes of ethics;
- Employee acknowledgments;
- Records of violations of code and responses to violations;
- List of access persons;
- Holdings and transaction reports (electronically);
- Record of adviser's approval of investments in IPOs and limited offerings.
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- Recordkeeping
- Copies of codes of ethics;
- Records of violations of code and responses to violations;
- Record of all persons required to make or review reports;
- Holdings and transaction reports;
- Record of adviser's approval of investments in IPOs and limited offerings.
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