Material Non-Public Information Risk Alert

On April 26, 2022, the Division of Examinations ("EXAMS") of the Securities and Exchange Commission ("SEC") released a Risk Alert ("Risk Alert")¹ relating to certain compliance issues observed by EXAMS that relate to the handling of material nonpublic information pursuant  to Section 204A ("Section 204A") of the Investment Advisers Act of 1940, as amended (the "Advisers Act"), and Rule 204A-1 (the "Code of Ethics Rule") promulgated under the Advisers Act (the Code of Ethics Rule).

As noted in the Risk Alert, Section 204A requires registered and unregistered investment advisers to establish, maintain, and enforce written policies and procedures to prevent the misuse of material non-public information ("MNPI"). The Code of Ethics Rule requires investment advisers that are registered (or required to be registered) under the Advisers Act to adopt a code of ethics.