How hedge fund advisers can reduce insider trading risk
Law enforcement officials are looking closely for insider trading at the advisers to hedge funds. This paper discusses some of the approaches that hedge fund managers use to prevent insider trading violations. They include avoiding agreements to keep information confidential and avoiding business communications between hedge fund personnel and close family members or personal friends. The paper also discusses steps to prevent receipt of information about investment opportunities that could mistakenly create a record that an adviser agreed to keep information confidential. Finally, it describes the many legitimate reasons that analysts at money managers have to communicate in private with senior management of public companies and ways hedge fund advisers can police the insider trading risks associated with those communications. For example, an adviser may use the terms of Reg FD to persuade a public company to make a public disclosure of information that had been conveyed inadvertently in a private conversation and that might, with hindsight, appear to be material and non-public.
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FromJournal of Securities Law, Regulation & Compliance, Apr. 2010,, 106-115
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LanguageEnglish