Access persons
Access persons are defined in Rule 204A-1 as supervised persons who have access to nonpublic information regarding clients’ purchase or sale of securities, are involved in making securities recommendations to clients, or who have access to recommendations that are nonpublic. A supervised
Restricted Lists.
The lists of issuers about which the access person has inside information, and prohibitions on personal trading in securities of any issuers on the restricted list.
Blackout Periods.
Blackout periods during which Access Persons are not permitted to engage in personal trading because client securities trades are being placed or recommendations are being made to clients. Many advisers use blackout periods to prevent Access Persons from trading ahead of clients or from trading on the same day client trades are placed.