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Managing Material Non-Public Information

Today’s private equity and hedge fund firms are more often than not offering multiple public and private markets investment strategies, which have introduced several risks that these new firms need to contemplate and manage. One of the top risks regulators are looking out for is access to and the potential misuse of material non-public information. To effectively manage the flow of information and monitor how that information is being used requires that firms adopt information barriers and insider trading policies and procedures, enhance the monitoring of personal and proprietary trading activities, and implement forensic testing programs. This article provides practical advice for CCOs on the steps they can take to ensure proper management of MNPI.

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