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Insider trading

Timothy P. Burke (Partner at Bingham McCutchen, (timothy.burke@bingham.com), Boston, MA, USA.)
Hope M. Jarkowski (Associate at Bingham McCutchen (hope.jarkowski@bingham.com) Washington, DC, USA.)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 20 March 2007

1038

Abstract

Purpose

This paper aims to remind investment firms of the importance of policies, procedures, and supervisory controls to detect the misuse of material, non‐public information.

Design/methodology/approach

Summarizes a recent increase in regulatory concern over insider trading and suggests that firms review their “information wall” procedures.

Findings

At a minimum, a firm's information wall procedures should include the following elements: surveillance of employee trading; supervision of interdepartmental communications, including “walling off” procedures and procedures for “wall crossings”; a review of proprietary training when the firm is in possession of material, non‐public information; employee training and education, and documentation.

Originality/value

Reviews the key elements of an investment firm's insider trading policies.

Keywords

Citation

Burke, T.P. and Jarkowski, H.M. (2007), "Insider trading", Journal of Investment Compliance, Vol. 8 No. 1, pp. 16-21. https://doi.org/10.1108/15285810710739328

Publisher

:

Emerald Group Publishing Limited

Copyright © 2007, Emerald Group Publishing Limited

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