Conflicts of Interest Questionnaires: Who Should Complete Them, When They Should Be Completed and How Managers Can Use Them Effectively (Part Two of Two)

Investment advisers must effectively manage conflicts of interest, particularly given the SEC’s continuing focus in this area. An adviser’s employees can be the source of potential and actual conflicts through their outside activities and relationships. Thus, investment advisers must gather information from employees on common situations and relationships that may give rise to conflicts. Conflicts of interest questionnaires are a commonly used tool for gathering this information. This second article in our two-part series explores how to use conflicts questionnaires, including who should be required to complete them, when they should be completed and how advisers should use the information gathered on these forms. The first article explained why investment advisers should use conflicts of interest questionnaires and described the areas the questionnaires should cover. See “SEC Sanctions Adviser That Failed to Disclose Sufficient Information About Its Conflicts of Interest in Recommending Wrap Fee Programs to Clients” (Oct. 11, 2018).

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