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Personal Trading · Rule 204A-1

Personal trading,
reviewed automatically.

RegFin pulls every executed trade from your advisors' held-away brokerage accounts (linked through Plaid or added by statement upload), then scores each one against the firm's restricted list, blackout windows, and client positions. Violations land in the CCO queue with the rule citation attached. Preclearance, holdings reports, and 204A-1 attestations live in the same place.

Held-away accounts via Plaid Holdings & quarterly transaction reports Code of Ethics ready
— personal trade · 2 violations live
Sarah ChenIAR · access person
Pending CCO review
— symbol
NVDA
— side
BUY
— quantity
250 shares
— account
Fidelity · ••4719
!
No preclearance on file

Trade executed without an approved preclearance request. NVDA is held across 14 of 38 client accounts. A personal trade in the same security and direction without prior approval is a Rule 204A-1 violation.

!
Front-running risk · client activity detected

Firm purchased NVDA for client accounts on May 12–14. Advisor's personal buy executed May 15 in the same direction within the 7-day lookback window.

204A-1
— SEC Code of Ethics rule
T+0
— Preclearance response time · clean requests
T+1
— Flag-to-CCO latency · nightly sync
0
— Quarterly attestation reminders to send
Employee trade monitoring & preclearance

Employee trade monitoring and preclearance, on autopilot.

Employee trade monitoring software automates personal-trading compliance under 17 CFR §275.204A-1: RegFin reviews every employee trade against the firm's restricted list, blackout windows, and client positions, runs preclearance before execution, and generates the holdings and quarterly transaction reports the rule requires.

Why this exists

Stop chasing brokerage statements in advisors' email.

The Code of Ethics workflow is the most paper-cut-heavy part of compliance. RegFin collapses it into a feed.

— The way most firms do it

Email, screenshots, spreadsheet.

1CCO sends quarterly Code of Ethics email blastDay 0
2Advisors send Fidelity / Schwab statements as PDFs7–14 days
3CCO transcribes holdings into compliance spreadsheet3–4 hrs
4Cross-check by hand against client positions and restricted list2–3 hrs
5Email an advisor to ask about a trade from 6 weeks ago+ deflection
~9 hrs
— Per CCO · per quarter
6 wks
— Avg. flag-to-review latency
— The RegFin workflow

Connect once. Review the exceptions.

1Advisor links held-away accounts via Plaid · or uploads a statement90 sec
2Executed trades + holdings sync nightly · foreverAutomatic
3Every trade scored against restricted list + client positionsNext day
4Only violations surface to CCO with reasoning + citationSame day
5Quarterly 204A-1 attestation auto-generated · advisor signs in app5 min
~15 min
— Per CCO · per quarter
Next day
— Flag-to-review latency
Capabilities

Every line item in the Code of Ethics workflow.

Preclearance requests

Advisors submit a planned trade in seconds. RegFin checks restricted list, client overlap, and blackout windows; clean requests auto-approve, anything that would violate a rule auto-denies with the citation, and judgment calls route to the CCO. The advisor still executes the trade themselves.

Restricted list

Maintain firmwide and team-level restricted lists with effective dates and decision logs. Lists sync automatically with your watchlist, IPO calendar, and any name flagged in research notes.

Blackout windows

Define blackouts around earnings, model rebalances, and research publication. RegFin enforces them per-security or per-team, with timeline visualization for CCO review.

Holdings & transaction reports

Initial and annual holdings reports plus quarterly transaction reports (all required under 204A-1) generate themselves from the synced data. Advisors review and sign in the app: no spreadsheets, no transcription errors, no missed accounts.

204A-1 attestations

Quarterly and annual attestations queue automatically. Each one cites the advisor's holdings, prior approvals, and any flags so signers know exactly what they're certifying.

Client overlap scoring

Every personal trade is scored against current client positions and recent transactions. Sequencing risk and front-running patterns surface before they become exam findings.

Held-away account feeds

Advisors link their held-away brokerage accounts through Plaid in about a minute. It's read-only, with no shared logins. For any account Plaid can't reach, drop in a brokerage statement and RegFin parses the trades and holdings.

Examiner export

One click produces a clean record for any IAR over any window: trades, approvals, attestations, supporting policies. The export ships with hash manifest and chain-of-custody log.

Post-trade surveillance

RegFin learns each advisor's baseline trading pattern and flags departures (unusual size, concentration, or sequencing) so problem trades surface even when they aren't on the restricted list. Every flag includes a citation to the rule it implicates.

Trade rules engine

Your firm's rules. Enforced automatically.

Define the rules once (restricted lists, blackout windows, holding periods, preclearance requirements, position limits) and RegFin enforces them on every trade, every day. Rules can auto-deny, flag for review, or auto-approve based on the risk level you set.

  • Preclearance required before execution: auto-deny if missing or expired
  • Front-running detection with configurable lookback windows
  • Blackout enforcement around earnings, rebalances, and research publication
  • Restricted and watch list checks with effective date tracking
  • Holding period minimums to catch short-term trading
  • De minimis thresholds to auto-clear small trades
— firm trade rules 8 active
Preclearance required
All access persons must obtain approval before executing personal trades
Auto-deny
Restricted list
Block trades in securities on the firm restricted or watch list
Auto-deny
Blackout window
No personal trades during earnings, model rebalance, or research periods
Auto-deny
!
Front-running detection
Flag personal trades in same direction as client activity within 7-day window
CCO review
!
30-day holding period
Flag short-term round-trips in the same security within 30 calendar days
CCO review
!
IPO & private placement
Require explicit CCO approval for new issues and limited offerings
CCO review
De minimis threshold
Auto-clear trades under $10,000 notional in broad-market ETFs
Auto-clear
Exempt securities
Auto-clear US Treasuries, money markets, and mutual funds per 204A-1(c)
Auto-clear
Data feeds

Every brokerage your advisors actually use.

RegFin reads held-away brokerage data through Plaid, which links to thousands of US brokerages and banks. Advisors connect their personal accounts once, and the data flows for as long as they stay enrolled. For any account Plaid can't reach, your advisors upload a brokerage statement and RegFin extracts the trades and holdings.

  • Held-away accounts linked via Plaid: thousands of US brokerages and banks
  • Statement upload for any account Plaid can't reach: the PDF is parsed automatically
  • Read-only · nightly transaction and holdings sync once linked
  • Cost-basis and lot-level detail where the source provides them
Connected accounts— 12 of 14 advisors enrolled
Linked via Plaid
Charles Schwabvia Plaid
Fidelityvia Plaid
Pershingvia Plaid
Goldman Sachs PWMvia Plaid
JPMorganvia Plaid
Morgan Stanleyvia Plaid
Vanguardvia Plaid
E*TRADEvia Plaid
Interactive Brokersvia Plaid
Robinhoodvia Plaid
Wealthfrontvia Plaid
Public.comvia Plaid
+ thousands more via Plaid · or upload a statement
The CCO view

One queue. Everything that needs a decision.

Clean trades clear themselves. Edge cases land here, with reasoning attached.

Personal trading
AllPendingFlaggedApproved
— last 30 days 4 pending
Advisor Symbol Side Qty Account Flag Status
SC
Sarah ChenIAR · access
NVDA Buy 250 Fidelity ••4719 Held in 14 client accts · 7d Review
RL
Robert LiangIAR · access
TSLA Sell 120 Schwab ••8201 Executed in model rebalance blackout Violation
MK
Maya KrishnanPM
VTI Buy 85 Vanguard ••0144 Cleared · auto
DK
Daniel KimIAR · access
AAPL Buy 40 Robinhood ••6622 De minimis · <$10k notional Cleared · auto
EM
Eleanor MendezCCO
META Buy 75 Schwab ••3018 Research blackout · earnings T-3 Review
JT
James TateIAR
SPY Sell 200 IBKR ••1190 Cleared · auto
FAQ

The questions a CCO actually asks.

No. Every connection is read-only. RegFin reads executed trades and holdings through Plaid (or from the brokerage statements your advisors upload), so we can't place, modify, cancel, or block orders at the broker. Preclearance requests live entirely within RegFin; when the firm denies one, the advisor simply doesn't execute the trade.
Advisors link their held-away brokerage accounts through Plaid, which reaches thousands of US brokerages: Schwab, Fidelity, Vanguard, Robinhood, Interactive Brokers, and many more. For any account Plaid can't reach, they upload a brokerage statement and RegFin extracts the trades and holdings. Either way, advisors connect once during onboarding and linked accounts sync nightly.
It's a two-step model. Advisors submit preclearance requests inside RegFin before they trade; the system auto-denies any request that would violate a firm rule (restricted list, blackout, hard-coded policy) and auto-approves the clean ones. Executed trades, including the ones that never went through preclearance, then sync from Plaid (or arrive by statement upload) and are scored again post-trade. Anything that looks like a violation, including a trade that executed without preclearance, lands in the CCO queue with a citation.
No. The Plaid feeds are read-only, and we don't believe a third-party compliance tool should sit in front of a personal brokerage order. What RegFin does block is the preclearance approval: if the request violates a rule, the request is denied with the citation, and the firm has a permanent record that the advisor was on notice before any trade was placed.
Your consultant reviews trades weeks later, from PDFs and spreadsheets you assembled. RegFin reviews every trade the night it clears, against the live restricted list, client positions, and the advisor's preclearance record. We don't replace your consultant; most firms keep theirs for strategy work. But they stop doing transcription.
Each "access person" record covers the advisor and the related accounts they have control or beneficial ownership over: typically spouse, dependents, and managed-by-advisor accounts. RegFin supports as many linked accounts as needed per access person, with separate attestation flows that make the relationships explicit on the record.
Onboarding · two weeks

Your next quarterly attestation. Already done.

Most firms connect every advisor's brokerage and run their first clean attestation cycle within the first calendar quarter of going live. We'll walk through your specific Code of Ethics policy in the demo.

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