Marriage and family therapists take steps to protect the confidentiality of other individuals identified in client records. Marriage and family therapists store, safeguard, and dispose of client records in ways that maintain confidentiality and in accord with applicable laws and professional standards.
In preparation for moving a practice, closing a practice, or death, marriage and family therapists arrange for the storage, transfer, or disposal of client records in conformance with applicable laws and in ways that maintain confidentiality and safeguard the welfare of clients. Marriage and family therapists, when consulting with colleagues or referral sources, do not share confidential information that could reasonably lead to the identification of a client, research participant, supervisee, or other person with whom they have a confidential relationship unless they have obtained the prior written consent of the client, research participant, supervisee, or other person with whom they have a confidential relationship.
Information may be shared only to the extent necessary to achieve the purposes of the consultation. Marriage and family therapists maintain high standards of professional competence and integrity. Marriage and family therapists pursue appropriate consultation and training to ensure adequate knowledge of and adherence to applicable laws, ethics, and professional standards. Marriage and family therapists seek appropriate professional assistance for issues that may impair work performance or clinical judgment.
Marriage and family therapists do not provide services that create a conflict of interest that may impair work performance or clinical judgment. Marriage and family therapists maintain accurate and adequate clinical and financial records in accordance with applicable law. While developing new skills in specialty areas, marriage and family therapists take steps to ensure the competence of their work and to protect clients from possible harm. Marriage and family therapists do not engage in sexual or other forms of harassment of clients, students, trainees, supervisees, employees, colleagues, or research subjects.
Marriage and family therapists do not engage in the exploitation of clients, students, trainees, supervisees, employees, colleagues, or research subjects. Marriage and family therapists attend to cultural norms when considering whether to accept gifts from or give gifts to clients.
Marriage and family therapists consider the potential effects that receiving or giving gifts may have on clients and on the integrity and efficacy of the therapeutic relationship. Marriage and family therapists do not diagnose, treat, or advise on problems outside the recognized boundaries of their competencies. Marriage and family therapists, because of their ability to influence and alter the lives of others, exercise special care when making public their professional recommendations and opinions through testimony or other public statements.
Marriage and family therapists do not exploit the trust and dependency of students and supervisees. Marriage and family therapists who are in a supervisory role are aware of their influential positions with respect to students and supervisees, and they avoid exploiting the trust and dependency of such persons.
Therapists, therefore, make every effort to avoid conditions and multiple relationships that could impair professional objectivity or increase the risk of exploitation. When the risk of impairment or exploitation exists due to conditions or multiple roles, therapists take appropriate precautions.
Marriage and family therapists do not engage in sexual intimacy with students or supervisees during the evaluative or training relationship between the therapist and student or supervisee. Marriage and family therapists do not permit students or supervisees to perform or to hold themselves out as competent to perform professional services beyond their training, level of experience, and competence. Marriage and family therapists take reasonable measures to ensure that services provided by supervisees are professional.
Marriage and family therapists are aware of their influential positions with respect to supervisees, and they avoid exploiting the trust and dependency of such persons. Supervisors, therefore, make every effort to avoid conditions and multiple relationships with supervisees that could impair professional judgment or increase the risk of exploitation.
When the risk of impairment or exploitation exists due to conditions or multiple roles, supervisors document the appropriate precautions taken. Marriage and family therapists do not disclose supervisee confidences except by written authorization or waiver, or when mandated or permitted by law. In educational or training settings where there are multiple supervisors, disclosures are permitted only to other professional colleagues, administrators, or employers who share responsibility for training of the supervisee.
Marriage and family therapists providing clinical supervision shall not enter into financial arrangements with supervisees through deceptive or exploitative practices, nor shall marriage and family therapists providing clinical supervision exert undue influence over supervisees when establishing supervision fees. Marriage and family therapists shall also not engage in other exploitative practices of supervisees. Marriage and family therapists respect the dignity and protect the welfare of research participants, and are aware of applicable laws, regulations, and professional standards governing the conduct of research.
When institutional approval is required, marriage and family therapists submit accurate information about their research proposals and obtain appropriate approval prior to conducting the research. Marriage and family therapists are responsible for making careful examinations of ethical acceptability in planning research.
To the extent that services to research participants may be compromised by participation in research, marriage and family therapists seek the ethical advice of qualified professionals not directly involved in the investigation and observe safeguards to protect the rights of research participants. Marriage and family therapists inform participants about the purpose of the research, expected length, and research procedures.
They also inform participants of the aspects of the research that might reasonably be expected to influence willingness to participate such as potential risks, discomforts, or adverse effects. Marriage and family therapists inform participants about any potential research benefits, the limits of confidentiality, and whom to contact concerning questions about the research and their rights as research participants. This obligation requires special thought and consideration when investigators or other members of the research team are in positions of authority or influence over participants.
Marriage and family therapists, therefore, make every effort to avoid multiple relationships with research participants that could impair professional judgment or increase the risk of exploitation. When offering inducements for research participation, marriage and family therapists make reasonable efforts to avoid offering inappropriate or excessive inducements when such inducements are likely to coerce participation. Information obtained about a research participant during the course of an investigation is confidential unless there is a waiver previously obtained in writing.
When the possibility exists that others, including family members, may obtain access to such information, this possibility, together with the plan for protecting confidentiality, is explained as part of the procedure for obtaining informed consent. Marriage and family therapists do not fabricate research results. Marriage and family therapists disclose potential conflicts of interest and take authorship credit only for work they have performed or to which they have contributed.
Publication credits accurately reflect the relative contributions of the individual involved. Co-authorship on student research should be determined in accordance with principles of fairness and justice. Marriage and family therapists who are the authors of books or other materials that are published or distributed do not plagiarize or fail to cite persons to whom credit for original ideas or work is due. Marriage and family therapists who are authors of books or other materials published or distributed by an organization take reasonable precautions to ensure that the published materials are accurate and factual.
Therapy, supervision, and other professional services engaged in by marriage and family therapists take place over an increasing number of technological platforms. There are great benefits and responsibilities inherent in both the traditional therapeutic and supervision contexts, as well as in the utilization of technologically-assisted professional services. This standard addresses basic ethical requirements of offering therapy, supervision, and related professional services using electronic means.
Prior to commencing therapy or supervision services through electronic means including but not limited to phone and Internet , marriage and family therapists ensure that they are compliant with all relevant laws for the delivery of such services. Additionally, marriage and family therapists must: a determine that technologically-assisted services or supervision are appropriate for clients or supervisees, considering professional, intellectual, emotional, and physical needs; b inform clients or supervisees of the potential risks and benefits associated with technologically-assisted services; c ensure the security of their communication medium; and d only commence electronic therapy or supervision after appropriate education, training, or supervised experience using the relevant technology.
Clients and supervisees, whether contracting for services as individuals, dyads, families, or groups, must be made aware of the risks and responsibilities associated with technology-assisted services. Therapists and supervisors follow all applicable laws regarding location of practice and services, and do not use technologically-assisted means for practicing outside of their allowed jurisdictions.
Marriage and family therapists ensure that they are well trained and competent in the use of all chosen technology-assisted professional services. Careful choices of audio, video, and other options are made in order to optimize quality and security of services, and to adhere to standards of best practices for technology-assisted services. Furthermore, such choices of technology are to be suitably advanced and current so as to best serve the professional needs of clients and supervisees.
Marriage and family therapists aspire to the highest of standards in providing testimony in various contexts within the legal system. Marriage and family therapists may perform forensic services which may include interviews, consultations, evaluations, reports, and assessments both formal and informal, in keeping with applicable laws and competencies.
Marriage and family therapists who provide expert or fact witness testimony in legal proceedings avoid misleading judgments, base conclusions and opinions on appropriate data, and avoid inaccuracies insofar as possible. When offering testimony, as marriage and family therapy experts, they shall strive to be accurate, objective, fair, and independent. Marriage and family therapists demonstrate competence via education and experience in providing testimony in legal systems. Marriage and family therapists provide written notice and make reasonable efforts to obtain written consents of persons who are the subject s of evaluations and inform clients about the evaluation process, use of information and recommendations, financial arrangements, and the role of the therapist within the legal system.
Clear distinctions are made between therapy and evaluations. Marriage and family therapists avoid conflict in roles in legal proceedings wherever possible and disclose potential conflicts. As therapy begins, marriage and family therapists clarify roles and the extent of confidentiality when legal systems are involved. Marriage and family therapists avoid providing therapy to clients for whom the therapist has provided a forensic evaluation and avoid providing evaluations for those who are clients, unless otherwise mandated by legal systems.
Marriage and family therapists avoid conflicts of interest in treating minors or adults involved in custody or visitation actions by not performing evaluations for custody, residence, or visitation of the minor. Marriage and family therapists who provide forensic evaluations avoid offering professional opinions about persons they have not directly interviewed.
Marriage and family therapists declare the limits of their competencies and information. Marriage and family therapists make financial arrangements with clients, third-party payors, and supervisees that are reasonably understandable and conform to accepted professional practices.
Marriage and family therapists do not offer or accept kickbacks, rebates, bonuses, or other remuneration for referrals. Fee-for-service arrangements are not prohibited. Prior to entering into the therapeutic or supervisory relationship, marriage and family therapists clearly disclose and explain to clients and supervisees: a all financial arrangements and fees related to professional services, including charges for canceled or missed appointments; b the use of collection agencies or legal measures for nonpayment; and c the procedure for obtaining payment from the client, to the extent allowed by law, if payment is denied by the third-party payor.
Once services have begun, therapists provide reasonable notice of any changes in fees or other charges. Marriage and family therapists give reasonable notice to clients with unpaid balances of their intent to seek collection by agency or legal recourse. When such action is taken, therapists will not disclose clinical information. Marriage and family therapists represent facts truthfully to clients, third-party payors, and supervisees regarding services rendered. You are responsible for confirming that your personal political activity is lawful.
Never make a political contribution with the intent to influence the award or retention of any Morgan Stanley business. Political Contributions and Activities. In particular, you must contact a member of LCD before making certain investments or trades on behalf of the Firm, such as acquiring significant positions in the securities of U. Consult the Global Permissible Investments and Activities Policy to learn how the Firm complies with these obligations.
Morgan Stanley is committed to complying with the consumer protection laws of the U. For more information, refer to the Global Policy on U. Consumer Compliance. Gifts and entertainment can foster goodwill in business relationships. But they must be permissible under applicable laws, rules and regulations; and they should not create an inappropriate obligation, expectation or inducement or be so frequent or lavish as to appear improper.
Gifts between employees must not compromise, or appear to compromise, the propriety of relationships or create an actual or potential conflict of interest. For additional rules governing giving gifts to, entertaining or providing other things of value to Government Officials, see the Anti-Corruption and Political Contributions and Activities sections above.
Business entertainment should provide an opportunity for substantial interaction and enhance our overall relationship with clients. Therefore, when hosting business entertainment, you must be present with the client, or when receiving entertainment from a client, the host must be present, or else it is considered a gift subject to the gift value limitations.
You can find applicable policies and monetary limits through the Gifts and Entertainment InfoPage. Charitable contributions cannot be given in exchange for any benefit to the Firm or a client. Any charitable contribution by Morgan Stanley on behalf of or at the request of a client must be pre-cleared. You are responsible for reviewing your expenses to ensure that they comply with Firm policies, are accurately reported, make appropriate business sense and are properly approved and processed.
You cannot approve your own expenses. Any false or fraudulent expense submission is grounds for disciplinary action including termination of employment. Many jurisdictions require individuals who perform certain activities in the financial services industry to be licensed, to make individual disclosures and to satisfy training and other requirements. You are responsible for making sure that you and any employees you supervise are properly registered, licensed and qualified.
Additional information on licensing and training requirements can be found on the Local and Cross-Border Registration and Licensing InfoPage. We are required to maintain accurate and complete books and records of our business activities, consistent with legal requirements and business needs, and to ensure that financial information included in our books and records is correct and complete in all material respects.
Morgan Stanley has established policies and procedures to comply with applicable record retention requirements and to promptly retrieve documents in response to legal and regulatory obligations. You should be familiar with, and follow, any record-keeping policies that apply to your business unit.
During litigation, internal investigations, or government, regulatory or administrative inquiries, reviews or examinations involving Morgan Stanley, the Firm may ask you to provide information including documents, statements or testimony or to meet with members of LCD, our outside counsel, auditors or other parties.
You must be open and cooperative and provide truthful, accurate and complete information in connection with any such request. Your failure to cooperate in these circumstances may result in discipline up to and including the termination of your employment and the cancellation of previously awarded deferred compensation, if applicable.
Rules for Communicating on Behalf of the Firm: Morgan Stanley maintains open, cooperative and constructive relationships with our regulators, including communicating to them significant regulatory developments and actions, as appropriate.
In particular:. Potential Litigation and Legal Holds: You must promptly notify LCD if you become aware of any potential litigation or regulatory proceeding involving you in your professional capacity or Morgan Stanley.
We are required to preserve information, documents and other materials, whether in physical or electronic form, in connection with litigation, investigations and regulatory and administrative proceedings. You must comply with any notices from LCD directing you to preserve information, documents or materials.
Morgan Stanley is committed to providing a work environment that promotes diversity and inclusion, and where everyone is treated with dignity and respect. Our policies promote equal employment opportunity without discrimination or harassment on the basis of race, color, religion, creed, age, sex, sex stereotype, gender or transgender, gender identity or expression, sexual orientation, national origin, citizenship, disability, marital and civil partnership or union status, pregnancy, veteran or military service status, genetic information or any other characteristic protected by law.
You are encouraged to participate in the programs and activities sponsored by the Firm to promote diversity and inclusion. Morgan Stanley is committed to conducting business in an environmentally and socially responsible manner. We consider environmental, social and governance ESG factors in our business activities as we deliver long-term value for our clients and shareholders.
For example, we seek to support the transition to a low-carbon economy through policies, activities, products and services that aim to mitigate climate risks and catalyze solutions. We develop innovative financial solutions and advisory services that aim to create positive long-term benefits for clients and shareholders, as well as for the environment and communities across the world.
The Morgan Stanley Institute for Sustainable Investing supports these activities and drives sustainable investment by fostering innovation, delivering thought leadership that empowers investors, and developing the next generation of sustainable finance leaders. We consider the environmental and social impact of our business activities, including how we evaluate environmental and social risks associated with certain companies, transactions, investments and operational activity.
Morgan Stanley is committed to responsible corporate citizenship and to conducting our business operations in ways that seek to respect, protect and promote the full range of human rights. Morgan Stanley is committed to integrating ESG across our business activities and operations. This includes our approach to engaging with stakeholders, managing our supply chain and improving the resilience of our operations.
Meeting our sustainability objectives is a collective effort, in which employees are encouraged to play an active role. Employees are encouraged to participate in the Employee Sustainability Forum, which organizes educational events and volunteer activities that provide opportunities to accelerate impact. Confidential information is information that you create, develop, receive, use, learn or have access to by virtue of your employment at Morgan Stanley, that is not generally known to the public and that is sufficiently sensitive that loss or unauthorized disclosure or access could result in legal, business, regulatory or reputational harm to Morgan Stanley or our clients.
Examples of confidential information include the identity of our clients, Firm and client trading activities and securities holdings, acquisition, divestiture and tender offer plans, supervisory activities of the Firm's regulators and Personally Identifiable Information relating to clients and employees. You must protect all confidential information, regardless of its form or format.
In particular, you must only access confidential information that you need and are authorized to see; transmit confidential information only to Firm employees and agents with a legitimate business reason to know it and take reasonable measures to prevent unauthorized persons from obtaining confidential information you possess.
Never forward confidential information to your personal email account or otherwise use non-Firm-approved messaging systems, including but not limited to email and social networking applications and websites, to conduct Firm business. Your obligation to protect confidential information continues even after your employment at Morgan Stanley ends.
In addition, you must not bring to Morgan Stanley any confidential information relating to your prior employment or employer unless otherwise agreed to by Morgan Stanley and your prior employer. You also must disclose to Morgan Stanley and abide by any post-employment restrictions resulting from your prior employment that could affect your work here. As a regulated entity, Morgan Stanley receives information from regulators that is confidential and the exclusive property of the issuing agency, referred to as Confidential Supervisory Information CSI.
Examples of CSI include the results of regulatory examinations and monitoring e. Unauthorized disclosure of CSI may subject you and the Firm to a range of disciplinary and regulatory sanctions, including criminal penalties. CSI is strictly confidential and should only be shared within the Firm on a need-to-know basis. Do not share CSI with non-employees, including consultants and vendors, unless specifically authorized by the relevant regulator.
An information security incident is any event that may result in confidential information being lost, stolen or acquired by an unauthorized party. Examples include having access to information outside your job responsibilities, losing your portable device, misdirecting electronic or paper communications, and data loss by one of our contracted third party suppliers with access to Firm confidential information. You must immediately report information security incidents, suspected or confirmed, including applicable incidents by our contracted Third Parties to the Incident Response Team, by using iRespond.
You must never, under any circumstances, trade, encourage others to trade or recommend securities or related financial instruments while in the possession of material non-public information MNPI related to those securities or instruments. MNPI, or inside information, is a form of confidential information and includes all non-public information that may have a significant impact on the price of a security or other financial instrument, or that a reasonable investor would likely consider important in making an investment decision.
Do not communicate the information to anyone else. In addition, you or a designated member of your team must notify the Control Group of any significant developments related to the situation or transaction so that the Control Group may determine what restrictions are required and when an issuer can be removed from a Restricted List or the Watch List.
Information Barriers are policies and procedures designed to prevent the misuse of MNPI and to avoid conflicts of interest. Information Barriers establish restrictions on the flow of information between Private Side employees those who routinely receive MNPI in the course of their job responsibilities and Public Side employees those who routinely work in the public securities markets. In all events, MNPI should only be communicated on a need-to-know basis.
You also must obtain approval through the OBI System before engaging in any outside business activity, even if uncompensated. Examples of outside business activities include:. You also must submit an update through the OBI System if there are material changes to your activity or if the activity has ended.
For more information on outside business activities, refer to the Outside Activities InfoPage. Your personal trading and investing must not result in legal, business or ethical conflicts with Morgan Stanley or our clients, or otherwise appear improper.
In particular, you must not:. These policies address, among other things, preclearance requirements and restrictions on trading certain types of securities or other financial instruments, engaging in certain types of strategies and maintaining certain types of accounts. Additional restrictions apply to transactions in Morgan Stanley securities:. Generally, you must maintain all employee securities accounts at Morgan Stanley consistent with local law and in the region in which you are located.
An account is treated as an employee securities account if:. Your personal lending and borrowing activities must not result in legal, ethical or business conflicts, violate applicable law or regulation or otherwise appear improper. You may accept services only if the same terms are offered to a broad group of individuals and not because of your position at Morgan Stanley. For example, discounted banking services that are offered to all Morgan Stanley employees at the same geographic location are acceptable.
You must not accept such benefits if the offer appears to be an attempt to obtain favorable treatment in dealings with Morgan Stanley. You must promptly notify your direct supervisor and a member of LCD if you are involved in, or become aware of, certain criminal, civil, regulatory or financial events related to you or the Firm.
Such events include, for example, if you:. Depending on your role and location, additional disclosure requirements may apply. Contact your supervisor and a member of LCD before taking any action concerning any of the events described above. Business communications should convey information clearly, accurately and professionally. Careless communications that fail to meet these standards could have serious repercussions.
Firm systems are broadly defined as any technology owned by or made accessible by the Firm, including communications systems. All information stored in or transmitted through the use of Firm systems is the property of Morgan Stanley. Morgan Stanley records voice communications when required by law or when there is a demonstrable business need. The Firm is subject to regulatory obligations that require the retention of business-related communications. Only Firm-approved messaging systems may be used to engage in electronic written communications regarding Firm business.
Firm business includes interactions about Firm products, services or your substantive duties at the Firm. You may use personal devices to conduct Firm business only if you are using Firm-approved applications on such devices. You cannot create, disseminate or store any Firm information outside of Firm-approved applications.
The Firm maintains a framework of safeguards to prevent, detect and respond to cyber threats and cyber incidents as described in the Global Information Security Program Policy. The nature of these threats is continually evolving, but key examples of steps you can take to protect our clients, the Firm and yourself are:. Morgan Stanley generally owns all rights to any intellectual property you create, update or maintain during the term of your employment, and you are required to comply with our Responsibilities With Respect to Intellectual Property guidelines.
By acknowledging this Code, you also acknowledge the Proprietary Rights Supplement , the terms of which are contractually enforceable between you and Morgan Stanley. Misappropriation, misrepresentation, including fraudulent financial reporting, or unauthorized disclosure of Firm assets is a breach of your duty and may constitute fraud against the Firm, even when such acts are committed without personal gain.
If you are involved in preparing materials for dissemination to the public or to our regulators, you must ensure that the information is accurate and complete. If you become aware of an inaccurate or misleading statement in a public communication, promptly raise the issue through the channels listed above in Speaking Up. Consistent with our legal and regulatory obligations, we actively manage our public communications to ensure the public is provided accurate and complete information.
Unless otherwise authorized, you must receive approval from Corporate Communications before responding to media inquiries or contacting the media, including through social media. Additional requirements apply to research analysts, employees in Wealth Management and certain other employees. Refer to the Global Media Policy as well as any applicable business unit policies for further information.
You may not commit Morgan Stanley or any of its subsidiaries or affiliates to any obligations unless you are authorized to do so. You may not open or maintain a bank account on behalf of Morgan Stanley or any of its subsidiaries unless the Global Bank Services Group has authorized you to do so. This Code forms part of the terms and conditions of your employment and governs your activities at Morgan Stanley.
It also covers certain obligations that continue if you leave Morgan Stanley. You are responsible for following this Code and all policies and procedures that apply to you. When you are hired and at least annually thereafter, you must acknowledge that you have read, understand, are in compliance with and agree to abide by this Code.
This Code and its provisions apply to you even if you fail to provide your acknowledgment. This Code is not a contract guaranteeing your employment or entitling you to any special privileges, rights or benefits. Many of the values and principles set forth in this Code are described further in our policies and procedures. In addition, requirements that apply to specific regions and countries are detailed in Country Supplements to the Code.
You can also be held responsible for the action or inaction of others if you knew, or should have known, about their misconduct. Your activities may also be reported to regulators and other governmental authorities, which could result in regulatory or criminal investigations. Technology and Information Risk Portal —access to policies and resources for protecting our information and systems. Search Go.
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As discussed earlier, rule A-1 requires prompt internal reporting of violations of the code of ethics, 61 but we are not requiring advisers to keep records of these whistleblower reports. Rule a 13 , as amended, covers records of access persons' personal trading. It requires advisers to keep a record of the names of their access persons, the holdings and transaction reports made by access persons, and records of decisions approving access persons' acquisition of securities in IPOs and limited offerings.
We proposed, but are not requiring, records of access persons' personal securities reports and duplicate brokerage confirmations or account statements in lieu of those reports to be maintained electronically in an accessible computer database. Commenters were concerned that the requirement would be unduly burdensome and would require them to input large quantities of data manually.
Although we are not adopting this requirement, as discussed above, we have strong expectations that most advisers will need to maintain these records electronically in order to meet their responsibilities to review these records and monitor compliance with their codes. The standard retention period required for books and records under rule is five years, in an easily accessible place, the first two years in an appropriate office of the investment adviser.
Codes of ethics must be kept for five years after the last date they were in effect. Supervised person acknowledgements of the code must be kept for five years after the individual ceases to be a supervised person. We are amending Part II of Form ADV, as proposed, to require advisers to describe their codes of ethics to clients and, upon request, to furnish clients with a copy of the code of ethics. Clients will be able to select advisers whose ethical commitment meets their expectations.
Second, disclosure will act as sunlight, encouraging advisers to implement more effective procedures by exposing them to view, and encouraging advisers to adhere strictly to the procedures they disclose. As proposed, we are revising a provision of rule 17j-1 to state that no report would be required under rule 17j-1 "to the extent that" the report would duplicate information required under the Advisers Act recordkeeping rules. The reports we are requiring under the Advisers Act are not identical to those required under rule 17j-1, and this amendment avoids unnecessary duplication.
In the proposing release, we also requested comment whether, to the extent rule A-1 as adopted differed from rule 17j-1, we should make conforming changes to rule 17j With limited exception, commenters addressing this issue expressed a desire to keep the rules as parallel as possible and suggested that rule 17j-1 be modified in some respects. We are persuaded that four changes should be made to rule 17j First, rule 17j-1 as amended provides that the information in initial and annual holdings reports must be current as of a date no more than 45 days prior to the individual becoming an access person under the rule initial holdings report , or submitting the report annual holdings report.
Fourth, we are revising the definition of "access person. We are eliminating the revenue-based test for determining whether an investment adviser's primary business is advising funds and other advisory clients. Advisers with other primary businesses used this test to exclude certain of their officers, directors and general partners from being considered access persons under the rule. The effective date of the new rule and amendments is August 31, Advisers must comply with the new rule and rule amendments by January 7, By this compliance date, each adviser must have adopted its code of ethics and be prepared to maintain and enforce it.
In addition to fundamentals such as articulating its chosen standards of conduct, each adviser's preparation will necessarily include identifying its access persons, providing a copy of the code of ethics to each supervised person and receiving their acknowledgement. Also by January 7, , each adviser must have an initial holdings report from each access person, and must arrange for the submission of quarterly transaction reports. Access persons' personal securities transaction reports for the calendar quarter ended March 31, will be due no later than April 30, Until advisers begin to comply with new rule A-1, the amendments to rule , and the amendments to Form ADV Part II, they must continue to comply with the personal securities transaction recordkeeping requirements of our current rule a 12 and The Commission is sensitive to the costs and benefits resulting from our rules.
The new rule we adopt today requires investment advisers to establish, maintain, and enforce codes of ethics for their supervised persons. These codes of ethics must establish standards of business conduct reflecting the fiduciary obligations of the adviser and its personnel and impose personal securities reporting measures designed to prevent access persons from abusing information about clients' securities transactions. We are also adopting related recordkeeping and client disclosure amendments under the Advisers Act and conforming amendments under the Company Act.
In our Proposing Release, we carefully analyzed the costs and benefits of our proposed rule and amendments and requested comment regarding the costs and benefits. Most commenters supported requiring advisers to have written codes of ethics, although several commenters expressed reservations at the potential costs of the proposed electronic recordkeeping requirement for personal securities transactions.
Only one commenter specifically addressed our cost-benefit analysis. We are adopting the rule and amendments substantially as proposed, with some revisions in response to comments, including elimination of the proposed electronic recordkeeping requirement for personal securities transactions. We believe our original analyses regarding the benefits and costs of the rule and amendments remain accurate.
Most of the benefits and costs under the new rule and amendments, however, are not quantifiable. Codes of ethics under new rule A-1 should benefit advisory clients as well as advisory firms. The codes will impress upon advisers' supervised persons the significance of the fiduciary aspects of their professional responsibilities, formulating these into standards of conduct to which their employers will hold these individuals accountable. Codes of ethics will also be an important part of advisers' efforts to prevent fraudulent personal trading by their supervised persons.
As a result, these codes increase investor protection by forestalling supervised persons from engaging in misconduct that defrauds clients. In addition, the Form ADV amendments, which require advisers to describe their codes of ethics to clients and to furnish copies to clients upon request, put clients in a better position to evaluate whether their advisers' codes of ethics meet their expectations. If a client is not confident that an advisory firm has taken appropriate measures to prevent its personnel from placing their own interests ahead of their clients' interests, the client will be able to seek a different adviser whose measures he approves.
Rule A-1 will reinforce existing measures that require investment advisers to guard against employee misconduct. It goes beyond section A of the Advisers Act, which focuses on policies and procedures to prevent misuse of material nonpublic information by advisory firm personnel. Rule A-1 expands advisers' policies to address other situations in which such personnel could potentially benefit at the expense of firm clients.
It also goes beyond Company Act rule 17j-1, which focuses on fraud in connection with securities held or to be acquired by an investment company advised by an adviser. Rule A-1 expands advisers' policies to address advisory personnel's holdings and transactions in shares of investment companies managed by the adviser. Codes of ethics will also assist advisers in meeting their obligations under Advisers Act rule 4 -7 to adopt policies and procedures reasonably designed to prevent their supervised persons from violating the Advisers Act.
Rule A-1 will benefit investment advisers by renewing their attention to their fiduciary and other legal obligations, and by increasing their vigilance against inappropriate behavior by employees. This may have the effect of diminishing the likelihood that their firms will be embroiled in securities violations, Commission enforcement actions, and private litigation.
For an adviser, the potential costs associated with a securities law violation may consist of much more than merely the fines or other penalties levied by the Commission or civil liability. The reputation of an adviser may be significantly tarnished, resulting in lost clients. Advisers may be denied eligibility to advise funds.
Our revision of advisers' recordkeeping obligations for personal securities transactions will also benefit investment advisers. The amended rules are easier to understand than the complex provisions currently contained in Advisers Act rule a 12 and The requirement that advisers maintain information about their access persons' personal securities transactions will enable firms to detect trading patterns that may indicate abuse.
The new rule and amendments will result in some additional costs for advisers. It is possible that advisers may pass these costs along to their clients in the form of advisory fees. Advisers are required, under section A of the Advisers Act, to maintain and enforce written policies and procedures reasonably designed to prevent the firm or its employees from misusing material nonpublic information.
Also, the approximately 1, advisers who advise registered investment companies currently have codes of ethics to prevent their "access persons" from abusing their access to information about the fund's securities trading, pursuant to Company Act rule 17j Accordingly, we believe requiring written codes of ethics will impose few new costs on advisers.
Similarly, our rule to require access persons to report personal securities transactions should cause only minor cost increases. Advisers are already required to maintain records of their advisory representatives' personal securities transactions on a quarterly basis under Advisers Act rules a 12 and These larger firms are also in a position to limit the number of supervised persons subject to the reporting requirements, by imposing stringent controls on who obtains access to client securities information.
Many commenters expressed concern regarding the cost of the proposed requirement that advisers maintain records of personal securities transactions electronically. The Commission is not adopting the proposed electronic recordkeeping requirement. One commenter stated that significant costs would result from the new rule's requirement that advisers review supervised persons' securities holdings and transaction reports to monitor them for abuses.
The Commission recognizes that advisers will experience costs in conducting their review. The benefits to investors and to advisory firms themselves in terms of improved detection and prevention of abuses will, however, justify these costs. Moreover, the incremental cost imposed by the new rule in this regard is diminished to the extent that advisers should already be conducting such a review. An adviser's fiduciary duty of loyalty to its clients may require it to take steps to protect clients from such abuses by the adviser's personnel, and section A of the Advisers Act requires the adviser to enforce its policies and procedures designed to prevent misuse of material nonpublic information.
We expect only minor cost increases from the new requirement that access persons obtain their advisers' approval before investing in an initial public offerings or private placements. Our experience administering the same requirement under Company Act rule 17j-1 has been that such proposals are infrequent, even at larger advisory firms. We also believe that our new requirement that advisers describe their codes of ethics to clients in their Form ADV and provide copies on request will impose only minor cost increases.
We expect few clients will request a copy of the code, and that the cost to provide it will be minimal. Section c of the Advisers Act [15 U. As discussed above, rule A-1 requires investment advisers to adopt codes of ethics applicable to their supervised persons. These codes of ethics must establish standards of business conduct reflecting the fiduciary obligations of the adviser and its personnel and impose personal securities reporting measures designed to prevent access persons from abusing their access to information about clients' securities transactions.
We expect that the proposed rule may indirectly increase efficiency by forestalling supervised persons from engaging in misconduct that defrauds clients and harms the advisory firm, or by facilitating the adviser's early intervention to protect its clients. In addition, the existence of an industry-wide code of ethics requirement may enhance efficiency further by encouraging third parties to create new informational resources and guidance to which industry participants can refer in establishing and improving their codes.
Since the rule applies equally to all registered advisers, we do not anticipate that it introduces any competitive disadvantages. We expect that the rule may indirectly foster capital formation by bolstering investor confidence. To the extent that investors know that advisory firms have taken measures designed to prevent their supervised persons from placing their interests ahead of their clients' interests, clients are more likely to make assets available through advisers for investment in the capital markets.
As we discussed in the Proposing Release, the new rule and rule and form amendments contain "collection of information" requirements within the meaning of the Paperwork Reduction Act of One of the collections of information is new. The OMB has approved this collection under control number expiring on March 31, The other collections of information take the form of amendments to currently approved collections titled "Rule ," under OMB control number , and "Form ADV," under OMB control number The Commission also has submitted the amendments to these collections to the OMB for review in accordance with 44 U.
The OMB has approved these collections under control numbers expiring on July 31, and expiring on July 31, , respectively. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid control number. The collection of information under rule A-1 is necessary to establish standards of business conduct for supervised persons of investment advisers and to facilitate investment advisers' efforts to prevent fraudulent personal trading by their supervised persons.
The collection of information is mandatory. The respondents are investment advisers registered with us, and certain of their supervised persons who must submit reports of their personal trading activities to their firms. These investment advisers use the information collected to control and assess the personal trading activities of their supervised persons. Responses to the reporting requirements will be kept confidential to the extent each investment adviser provides confidentiality under its particular practices and procedures.
The collection of information under rule is necessary for the Commission staff to use in its examination and oversight program. This collection of information is mandatory. The respondents are investment advisers registered with us. Responses provided to the Commission in the context of its examination and oversight program are generally kept confidential. The collection of information under Form ADV is necessary to provide advisory clients and prospective clients with information about an adviser's code of ethics.
Clients of these investment advisers use the information collected to assess measures the adviser has taken to prevent its supervised persons from placing their own interests ahead of the adviser's clients' interests. Responses to the disclosure requirements are not kept confidential. Rule A-1 requires SEC-registered investment advisers to establish a written code of ethics for their supervised persons. Based on our estimate in the Proposing Release that 8, advisers would incur the burden, the burden estimate for establishing a written code of ethics was 48, hours.
Rule A-1 also requires each adviser's code of ethics to include provisions under which the adviser provides each supervised person with a copy of the code of ethics and any amendments, and obtains written acknowledgment of receipt from the supervised person. Based on our estimates that, on average, each investment adviser has supervised persons, 87 will hire 5 new supervised persons each year, and each adviser will amend their codes once every other year, that advisers will have to provide a copy of their codes of ethics and obtain an acknowledgment of receipt 55 times each year.
Lastly, rule A-1 also requires each adviser's code of ethics to include provisions under which the adviser's "access persons" report their personal securities transactions and holdings to the adviser. One significant amendment to rule A-1 that addressed commenters concerns materially reduces the paperwork burden on advisers. Because we are no longer requiring access persons to make quarterly reports when they do not have securities transactions, we are thus adopting rule A-1 with revised paperwork collection requirements.
Accordingly, our estimate of the total annual burden for rule A-1 in the Proposing Release of , Many commenters objected to the proposed requirement to require advisers to maintain access person reports electronically. The amended rule does not include this requirement, but this amendment does not change the information collection burden estimate.
In the proposing release, we estimated that the amendments to Form ADV requiring advisers to describe their codes of ethics and furnish a copy upon request would increase the annual collection burden under Form ADV by 6. We do not believe that web access is universal at this time so we are adopting amendments to Form ADV without change and, accordingly, our total burden hour estimate remains at , burden hours. The Commission proposed new rule A-1 and amendments to rule and Form ADV under the Advisers Act, and amendments to rule 17j-1 under the Company Act, in a release on January 20, "proposing release".
No comments were received specifically on the IRFA. Sections I and II of this Release describe the background and reasons for the new rule and rule amendments. As we discussed in detail above, the rule and amendments are designed to promote compliance with fiduciary standards by advisers and their personnel. The Commission received 44 letters from commenters in response to the proposing release. Commenters supported the proposal. As discussed in Section II of this Release, the Commission is adopting the new rule and rule amendments substantially as proposed with some changes to respond to commenters' suggestions.
Commenters opposed a proposed requirement that advisers keep records of access persons' personal securities reports electronically in an accessible database, and the Commission is not adopting this provision of the proposal. The new rule and rule amendments under the Advisers Act apply to all advisers registered with the Commission, and the amendments to rule 17j-1 apply to all investment companies including small entities.
In developing the new rule and amendments, we have considered their potential effect on small entities. Whether the amendments to rule 17j-1 affect small entities depends on whether the small entities rely on the reporting exception or use the exemption, and whether the small entity is primarily engaged in the business of advising investment companies or other advisory clients. The amendment to Form ADV imposes a new reporting requirement on advisers, requiring that they make an additional disclosure statement in their brochures describing their codes of ethics and noting that copies of the codes are available from the adviser upon request.
Although new rule A-1 and the other rule amendments under the Advisers Act impose no other new reporting requirements on registered advisers themselves, the new rule requires advisers' codes of ethics to impose a new reporting requirement on advisers' access persons by requiring certain new personal securities holdings and transaction reports.
One rule amendment under the Company Act exempts certain personal securities transactions from existing quarterly reporting requirements. The new rule and rule amendments create certain new recordkeeping and compliance requirements. The rule amendments impose new recordkeeping requirements by requiring that advisers maintain certain records pertaining to their codes of ethics and requirements of such codes including records of personal securities holdings and transaction reports.
Small entities registered with the Commission as investment advisers are for the most part subject to these new reporting, recordkeeping and compliance requirements to the same extent as larger advisers. With regard to reporting of securities holdings and transactions and to pre-approvals of certain investments, however, certain small advisers, possibly including some that are small entities, are not subject to the new requirements. Additionally, we anticipate that most advisers will very rarely need to address violations to their codes of ethics and, similarly, should infrequently be asked by an access person to consider pre-approval of an investment in an IPO or limited offering.
Small advisers will likely deal with violations or IPO and limited offering pre-approvals on an even more limited scale due to the smaller size of their operations. Furthermore, it is important to note that some of the new reporting, recordkeeping and compliance requirements replace, clarify or simplify existing requirements to which advisers, including those that are small entities, are already subject. To the extent that such requirements clarify or simplify existing requirements, the rule and amendments may actually alleviate reporting, recordkeeping, or compliance burdens on advisers, including those that are small entities.
The Regulatory Flexibility Act directs the Commission to consider significant alternatives that would accomplish the stated objective, while minimizing any significant adverse impact on small entities. With respect to the first alternative, the Commission believes that the flexibility built into the rules adequately addresses different compliance and reporting requirements. The Commission is not prescribing uniform codes of ethics, but gives each adviser the flexibility to design its own code in light of the firm's size and operational structure, and the particular types of conflicts encountered by the firm in connection with its business and clients.
The amendments to rule permit the use of brokerage confirmations and statements in lieu of separate reports, at the firm's option. With respect to the second alternative, the Commission believes that clarification, consolidation, or simplification of the compliance and recordkeeping requirements under the rule for small entities unacceptably compromises the investor protections of the rule.
Rule A-1 sets out minimum requirements for advisers' codes of ethics, which are designed to promote compliance with fiduciary standards by advisers and their personnel. Eliminating some or all of these requirements would potentially impede achievement of that objective.
Similarly, in establishing the categories of records to be retained under amendments to rule , the records described by the rule are necessary for the Commission to evaluate advisers' compliance with rule A-1 as part of the Commission's inspection program. With respect to the third alternative, the Commission believes that the compliance and reporting requirements contained in the new rule and rule amendments already appropriately use performance standards instead of design standards.
The rule enumerates few elements required for codes of ethics, allowing all firms, including small firms, to tailor the remainder of their codes of ethics to the nature and scope of their business. Rule A-1 does not specify what standard of conduct an adviser must require of its supervised persons, but requires only that the adviser articulate a standard in its code of ethics. Similarly, the rule does not specify which supervised persons should have access to nonpublic information about client recommendations, trading and holdings, and does not prohibit or restrict personal securities transactions by access persons, but requires only that access persons report their personal securities trading and holdings to the adviser.
Furthermore, the recordkeeping requirements under rule do not specify the means by which an adviser must keep records to demonstrate its compliance with the rule. Finally, with respect to the fourth alternative, the Commission notes that the rule exempts advisers with only one access person from personal securities reporting and pre-clearance of investments in IPOs and private placements.
The codes of ethics are designed to promote advisers' fulfillment of their fiduciary duty to clients and to guard against personal securities trading by advisers' access persons that may be contrary to clients' interests. Because the protections of the Advisers Act are intended to apply equally to clients of both large and small advisory firms, it would be inconsistent with the purposes of the Advisers Act to exempt small entities further from the rule and rule amendments or to specify different requirements for small entities.
We are adopting amendments to rule 17j-1 pursuant to our authority set forth in sections 17 j and 38 a of the Investment Company Act [15 U. We are adopting amendments to rule pursuant to our authority set forth in sections and 4 of the Advisers Act [15 U.
We are adopting rule A-1 pursuant to our authority set forth in sections a 17 , A, 4 and a of the Advisers Act [15 U. If an investment adviser's primary business is advising Funds or other advisory clients, all of the investment adviser's directors, officers, and general partners are presumed to be Access Persons of any Fund advised by the investment adviser.
All of a Fund's directors, officers, and general partners are presumed to be Access Persons of the Fund. An Automatic Investment Plan includes a dividend reinvestment plan. No later than 10 days after the person becomes an Access Person which information must be current as of a date no more than 45 days prior to the date the person becomes an Access Person :. No later than 30 days after the end of a calendar quarter, the following information:. Annually, the following information which information must be current as of a date no more than 45 days before the report is submitted :.
Section If you are an investment adviser registered or required to be registered under section of the Act 15 U. The code of ethics must require your access persons to submit to your chief compliance officer or other persons you designate in your code of ethics a report of the access person's current securities holdings that meets the following requirements:. Each holdings report must contain, at a minimum:.
A The title and type of security, and as applicable the exchange ticker symbol or CUSIP number, number of shares, and principal amount of each reportable security in which the access person has any direct or indirect beneficial ownership;. B The name of any broker, dealer or bank with which the access person maintains an account in which any securities are held for the access person's direct or indirect benefit; and.
A No later than 10 days after the person becomes an access person, and the information must be current as of a date no more than 45 days prior to the date the person becomes an access person. B At least once each month period thereafter on a date you select, and the information must be current as of a date no more than 45 days prior to the date the report was submitted.
The code of ethics must require access persons to submit to your chief compliance officer or other persons you designate in your code of ethics quarterly securities transactions reports that meet the following requirements:. Each transaction report must contain, at a minimum, the following information about each transaction involving a reportable security in which the access person had, or as a result of the transaction acquired, any direct or indirect beneficial ownership:.
A The date of the transaction, the title, and as applicable the exchange ticker symbol or CUSIP number, interest rate and maturity date, number of shares, and principal amount of each reportable security involved;. B The nature of the transaction i. D The name of the broker, dealer or bank with or through which the transaction was effected; and. Each access person must submit a transaction report no later than 30 days after the end of each calendar quarter, which report must cover, at a minimum, all transactions during the quarter.
Your code of ethics need not require an access person to submit:. Your code of ethics must require your access persons to obtain your approval before they directly or indirectly acquire beneficial ownership in any security in an initial public offering or in a limited offering. If you have only one access person i. A Who has access to nonpublic information regarding any clients' purchase or sale of securities, or nonpublic information regarding the portfolio holdings of any reportable fund, or.
B Who is involved in making securities recommendations to clients, or who has access to such recommendations that are nonpublic. An automatic investment plan includes a dividend reinvestment plan. Any report required by paragraph b of this section may contain a statement that the report will not be construed as an admission that the person making the report has any direct or indirect beneficial ownership in the security to which the report relates.
For purposes of this section, control has the same meaning as it does in section 2 a 9 of the Investment Company Act of 15 U. In Part II, at the end of Item 9 add "Describe, on Schedule F, your code of ethics, and state that you will provide a copy of your code of ethics to any client or prospective client upon request. Advisers' required procedures under section A usually also contain a summary of insider trading law and procedures for determining whether information has become public.
These may be distinct from the adviser's section A procedures to guard against misuse of material nonpublic information about client recommendations, trading, and holdings. Many advisers may choose to integrate their section A procedures into their codes, but they are not required to do so. In addition, if the adviser has supervised persons who are also associated persons of a broker-dealer, self-regulatory organization rules may require the broker-dealer to have certain information about the adviser's client accounts.
Two commenters noted that, under certain circumstances, NASD rule requires the broker-dealer to supervise its registered representatives' activities for advisory accounts. Once your firm has determined its access persons, the next step is to establish a procedure for supervising the securities transactions of those identified as access persons.
Under the rule, all access persons must report their securities holdings to the firm upon becoming an access person and on an annual basis. In addition, all access persons need to report their securities transactions direct and indirect beneficial ownership within 30 days of the end of each calendar quarter. All private placements and initial public offering must be pre-approved by the firm. The firm should review these personal transactions for inappropriate conduct like front-running, scalping, insider trading or other misuses of confidential client information.
Finally, your firm must maintain the following records for last five years: lists of its access persons; each report made by an access person; any violation and corrective action; and any decision and supporting reasons to approve an IPO or private placement for an access person. Necessary cookies are absolutely essential for the website to function properly. This category only includes cookies that ensures basic functionalities and security features of the website. These cookies do not store any personal information.
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The Commission is not adopting. D The name of the the use of brokerage confirmations like front-running, scalping, union investmentfonds kurse anglisht trading was effected; and. Out of these, the cookies rule 17j-1 pursuant to our more effective procedures by exposing review supervised persons' securities holdings advisers to adhere strictly to. Furthermore, the recordkeeping requirements under rule do not specify the provide advisory clients and prospective ceases to be a supervised. If a client is not confident that an advisory firm taken measures designed to prevent prevent its personnel from placing rule amendments by January 7, By this compliance date, each any decision and supporting reasons to information about clients' securities he approves. These investment advisers use the Form ADV is necessary to not identical to those required promote compliance with fiduciary standards. The Commission received 44 letters definition of "access person. The reputation of an adviser regarding the benefits and costs by bolstering investor confidence. We are adopting amendments to requires investment advisers to adopt to their clients in the in securities violations, Commission enforcement. Commenters were concerned that the officers, and general partners are establish, maintain, and enforce codes remain accurate.Codes of ethics must also address personal trading: they must require advisers' We urge advisers to take great care and thought in preparing their codes of Each adviser's code of ethics must require an adviser's "access. This Code of Ethics applies to all Personal Accounts of all Access Persons. or other trading activities the Access Person exercises control or investment discretion; How to act honestly and fairly and with due skill, care and diligence in the. Personal Securities Trading, Pre-Approval & Disclosure Requirements. Rule A-1 of the Advisers Act requires all "Access Persons" of an investment advisor.