The SEC proposed an amendment to the 1940 Act yesterday that would require all mutual fund and other investment advisors to adopt a code of ethics that would apply to all supervisors, portfolio managers and other key personnel.

One of the changes would require certain fund employees to pre-clear personal investments through private offerings or initial public offerings. And a fund’s chief compliance officer would be ultimately responsible for any violations of non-disclosure of holdings or recommendations, including those related to mutual funds run by the advisor or an affiliate.

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