Trading Practices, Portfolio Compliance and Related Enforcement Cases

Jeffrey Blumberg spoke on "Trading Practices, Portfolio Compliance and Related Enforcement Cases" at the Investment Adviser Certified Compliance Professional (IACCP) Program Symposium.

As a fiduciary, an investment adviser has many obligations to their client including developing, implementing and testing policies, procedures and disclosures to ensure proper trading practices. Jeffrey offered an overview of the trading process and appropriate best practices, and provided “hands-on” compliance solutions for these mission-critical areas: fiduciary duty and client investment objectives/restrictions, aggregation, allocation, personal and proprietary trading, principal and agency cross transactions, side-by-side management, effective supervisory systems, and special considerations for hedge funds.

The session also focused on the critical risk area of portfolio compliance. Managing a client’s portfolio within relevant limitations and objectives is one of the most important fiduciary responsibilities of an investment adviser. Investment advisers are responsible for knowing their clients’ investment policies, guidelines and mandates, as well as any other applicable investment restrictions, and for managing their clients’ accounts strictly in accordance with such guidelines and restrictions. The SEC views consistency of portfolio management decisions with clients’ mandates as a primary internal-control process.