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 on that 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 that information. This two-part series covers the fundamentals of conflicts of interest questionnaires. This second article 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 those forms. The first article explained why investment advisers should use conflicts of interest questionnaires and described the areas the questionnaires should cover. See “Conflicts From Managing Multiple Funds and Other Current Challenges to Effective Compliance at PE Funds” (Nov. 30, 2021).

To read the full article

Continue reading your article with a PELR subscription.