Nonpublic Info Compliance After SEC's Fund Manager Alert

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By Michael Osnato, Meaghan Kelly and Allison Bernbach (May 9, 2022, 6:57 PM EDT) — The Division of Examinations of the U.S. Securities and Exchange Commission recently published a risk alert[1] highlighting deficiencies identified during recent examinations of investment advisers concerning compliance issues related to Section 204A of the Investment Advisers Act[2] and Rule 204A-1, known as the code of ethics rule.[3]

Consistent with the general trend toward a more expansive SEC view of what constitutes material, nonpublic information, or MNPI, as reflected in several recent enforcement actions — certain of which are alluded to but not cited — the risk alert reflects heightened regulatory expectations with respect to how investment advisers monitor their intake and…

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