Section A - Creating and Managing a Hedge Fund Business » 4. Employees » 2. Training

Provider: MFA

Practice:	Guidance:
A Hedge Fund Manager should adequately train all personnel to be familiar and comply with its compliance policies and procedures.	A Hedge Fund Manager should develop procedures to ensure that employees understand and accept its compliance policies and procedures. These procedures may include a verification of an employee’s understanding and acceptance of the policies and procedures, which may take the form of a written attestation or in such other form as the Hedge Fund Manager determines is appropriate for its business. A Hedge Fund Manager should require new employees to undergo verification upon the commencement of employment and existing employees to renew their verification at appropriate intervals. Areas in which a Hedge Fund Manager should consider training employees include: misuse of material, non-public information; use of third-party paid consultants; AML; protection of investors’ confidential information; securities reporting requirements; etc. A Hedge Fund Manager may customize training by job functions. Other subject areas may require training of all personnel (e.g., personal trading, anti-discrimination, anti-sexual harassment, gifts, and entertainment). A Hedge Fund Manager should devote adequate resources to ongoing training programs for its personnel, which should include appropriate follow-up training, as applicable.

Practice:

Guidance:

A Hedge Fund Manager should adequately train all personnel to be familiar and comply with its compliance policies and procedures.

A Hedge Fund Manager should develop procedures to ensure that employees understand and accept its compliance policies and procedures. These procedures may include a verification of an employee’s understanding and acceptance of the policies and procedures, which may take the form of a written attestation or in such other form as the Hedge Fund Manager determines is appropriate for its business. A Hedge Fund Manager should require new employees to undergo verification upon the commencement of employment and existing employees to renew their verification at appropriate intervals.

Areas in which a Hedge Fund Manager should consider training employees include:

misuse of material, non-public information; use of third-party paid consultants;
AML;
protection of investors’ confidential information;
securities reporting requirements; etc.

A Hedge Fund Manager may customize training by job functions. Other subject areas may require training of all personnel (e.g., personal trading, anti-discrimination, anti-sexual harassment, gifts, and entertainment). A Hedge Fund Manager should devote adequate resources to ongoing training programs for its personnel, which should include appropriate follow-up training, as applicable.