Foley Partner Patrick Daugherty was quoted in an article titled “Key Elements of a Hedge Fund Manager’s Insider Trading Policies and Procedures” in the October 29, 2009 issue of The Hedge Fund Law Report. Daugherty discusses the elements of an effective insider trading policy, as well as the importance to hedge fund managers of focusing and training personnel on comprehensive and strategy-specific insider trading policies and procedures. He notes that the SEC and the U.S. Attorney’s Office are investigating dozens of insider trading cases involving hedge funds, adding that if a hedge fund manager does not have a compliance manual, it is time to create one.
