NASAA Ethics Rule
The NASAA Model Rule on Ethics establishes requirements for codes of ethics at state-registered investment advisory firms, covering personal trading policies, insider trading prevention, gift and entertainment rules, outside business activities, and conflict of interest management.
Key Requirements
Written Code of Ethics
Every registered investment advisor must adopt and maintain a written code of ethics that sets forth standards of conduct for all supervised persons.
Personal Trading Pre-Clearance
Access persons must obtain pre-clearance before executing personal securities transactions in reportable securities to prevent conflicts with client trading.
Holdings and Transaction Reporting
Access persons must submit initial and annual holdings reports and quarterly transaction reports covering all personal securities accounts.
Insider Trading Prevention
The code of ethics must include policies and procedures designed to prevent the misuse of material non-public information (MNPI).
Gift and Entertainment Policies
Rules governing the giving and receiving of gifts and entertainment to prevent conflicts of interest and inappropriate influence on advisory activities.
Outside Business Activity Disclosure
Supervised persons must disclose all outside business activities that could create conflicts of interest with their advisory responsibilities.
State Adoption Status
Adoption of NASAA model rules varies by state. Some states adopt the model rule directly, while others have their own rules covering the same requirements.
Visit the State Adoption Tracker for a complete per-state breakdown. Data sourced from NASAA model rule matrix and NV 2024 Legislative Survey. Last verified March 2026.
Common Violations
Avoid these frequently cited deficiencies during state examinations.
Missing Pre-Clearance Records
Access persons trading in reportable securities without obtaining proper pre-clearance approval or without maintaining documentation of the approval process.
Late or Missing Holdings Reports
Failure to collect initial holdings reports within the required timeframe or missing annual/quarterly reporting deadlines.
Inadequate Code of Ethics
Having a code of ethics that does not cover all required topics or that has not been updated to reflect current regulations and firm practices.
Undisclosed Outside Business Activities
Supervised persons engaging in outside business activities without proper disclosure and approval from the compliance department.
Gift Policy Violations
Accepting or giving gifts above policy limits without proper approval, or failing to maintain a gift and entertainment log.
Best Practices
Frequently Asked Questions
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