Investment advisers—both registered and unregistered—should take stock and be mindful of all potential points of access they have to MNPI. The SEC will be looking closely at policies and practices concerning:
- Due diligence surrounding providers of alt data.
- Identifying and tracking relationships with clients and corporate executives or financial professional investors who may have MNPI.
- Tracking and logging expert network calls and reviewing trading of supervised persons.
- Trading investments on a firm’s restricted list.Ensuring that clients are appropriately allocated investment opportunities, before the adviser or its employees may act on them.
Source: SEC Flags Deficiencies in Investment Adviser MNPI Compliance Practices | Morrison Foerster