Posted under Insider Trading, SEC on November 5th, 2009 by Judith Gross
With the arrest of 13 additional individuals and entities in the Galleon case, we urgently see the need for hedge fund compliance to beef up in two areas:
OPERATIONAL RISK CONTOLS- Hedge Funds need to understand and monitor where and how the information being traded on is generated.
TRAINING - Employees need to understand precisely what [...]
Posted under Compliance Program, Insider Trading, Regulation on January 26th, 2009 by Judith Gross
Q: If hedge fund compliance professionals could roll back time and make one form of technology disappear, what would it be?
A: Clearly, without question, hands down: email (and its cousin, instant messages)
No matter how many warnings and explanations are given, the spate of wacky, stupid and worst of all, self-implicating, emails and IM’s by hedge fund [...]
Posted under Compliance Program, Conflicts of Interest, Insider Trading, Trading on November 18th, 2008 by Judith Gross
For hedge fund compliance professionals, a primary part of their job responsibility is to prevent or detect front-running.
In the hedge fund context, front-running is generally defined as a manager or employee taking a position in an equity security prior to the fund, or filling an order for their own account prior to the fund’s. [...]
Posted under Insider Trading, Trading on August 13th, 2008 by Judith Gross
Richard Ketchum CNBC Interview 8/13/08 In a landmark agreement announced today, the NY Stock Exchangeand FINRA have taken responsibility for the monitoring of insider trading for ten US exchanges. NYSE and NYSE-Arca listed securities trading will now be monitored by NYSE, and AMEX and NASDAQ-listed securities trading will be overseen by FINRA.
This brings surveillance, investigation [...]
Posted under Insider Trading, SEC, Training on June 2nd, 2008 by Judith Gross
Last week’s indictment by federal prosecutors of an Ernst & Young partner for “tipping” in an insider trading scheme highlights the need for training of hedge fund employees about a very critical, but often over-looked, component of these cases — namely, that a person can be subject to criminal charges for “tipping” regardless of whether [...]