Practice question, Code of ethics
Produce your access person list, the holdings and transaction reports for a sample quarter, the attestations and any exemptions granted, and show who reviewed the reports and when.
Taft practice question: not an official regulator question. SEC Division of Examinations, United States (federal). For SEC-registered investment advisers. Evidence category: Personal trading records.
Not legal advice. A practice prompt for rehearsing how your team explains its controls and evidence. No scoring, no model answer, no implication that a regulator will ask these words.
Authored by Taft. Last checked 2026-11-09. All questions.
Why it is relevant
The typical initial request list includes code of ethics attestations, exemptions from the code for supervised persons, and reports of securities transactions reported by access persons.
Sources: [1] Attachment, Conflicts of Interest and Insider Trading
Evidence to locate
Suggested, not mandatory. A regulator's actual request list governs.
No evidence cues listed.
Follow-up prompts
How is a late or missing report handled?
Applicability
- Applies to
- Advisers registered or required to be registered with the SEC. Report timing is quoted in the deadline references.
- Does not apply to
- Not stated.
Cite
Cite the official source first. Then: Taft Compliance Group, Exam-prep toolkit (draft), question q-code-of-ethics-reports, https://taftcompliance.com/resources/exam-prep-toolkit/questions/q-code-of-ethics-reports, last checked 2026-11-09.
Sources
U.S. Securities and Exchange Commission, Division of Examinations, Risk Alert: Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents (staff statement). regulator guidance. Attachment, Typical Initial Information Examiners Request of Investment Advisers: Conflicts of Interest and Insider Trading; Marketing and Advertising; Custody.
https://www.sec.gov/files/risk-alert-ia-risk-and-requesting-documents-090623.pdf
Checked 2026-11-09; published 2023-09-06.
Supporting passage
Code of Ethics attestations. Exemptions from Code of Ethics for supervised persons. Reports of securities transactions reported by access persons. Fee splitting or revenue sharing arrangements. Testimonials and endorsements, including payments made and compensation received. Third-party ratings and rankings. Custodian identification and contact information for entities that maintain custody of client assets. Surprise examination documentation, such as engagement letters, client account lists, and reports, results, and recommendations. Auditor engagement letters, opinions, and findings. Custodial confirmation of positions for specific clients.
Changes to this question
No released changes.