Code of Ethics Template for RIAs
Advisers Act Rule 204A-1 and Section 204A
Standards of conduct, personal trading and reporting, pre-clearance, inside information, gifts and entertainment, political contributions and outside business activities, fitted to how your firm actually works.
Included in Solo, Firm and Firm Plus. 14-day free trial.
What the rule requires
Rule 204A-1 requires an SEC-registered adviser to adopt a written code of ethics that sets a standard of business conduct reflecting its fiduciary duty, requires compliance with the federal securities laws, and requires access persons to report their personal securities holdings and transactions.
Access persons file an initial and annual holdings report and quarterly transaction reports, must get approval before acquiring securities in an IPO or a limited offering, and must report violations of the code promptly to the CCO. Every supervised person acknowledges receiving the code. Section 204A separately requires policies to prevent the misuse of material non-public information.
What the policy covers
The sections of Luna's model Code of Ethics policy. Your draft includes only the clauses that apply to your firm.
- 1Introduction and purpose
- 2Standards of conduct and compliance with law
- 3Reporting violations
- 4Conflicts of interest
- 5Personal trading and reporting
- 6Insider trading and material non-public information
- 7Gifts and entertainment
- 8Political contributions and pay-to-play
- 9Outside business activities
- 10Records, administration and delivery
What Luna asks you
A few of the questions that shape the draft:
- Whether the CCO is the firm's only access person
- Which personal trades need pre-clearance, and for how long approval lasts
- Gift and entertainment limits, given and received
- Whether the firm has government clients, which brings in pay-to-play
How drafting works
- 01Answer questions about your firm
Plain questions about how you operate. Where there is a common answer, Luna suggests it; where you are not sure, say so and it is flagged rather than assumed.
- 02Luna drafts the policy
Only the clauses that apply to your firm, in your firm's name, each traced to the rule or choice it comes from.
- 03Review what is left
Anything unanswered is marked in the text and listed for you, and the policy cannot be approved until each is settled.
- 04Edit, approve and roll out
It is your policy: edit it like any other, approve it, and have employees acknowledge it in the same place.
Read the source
Other policies
A summary of what the rule requires, current as of October 2026, so you can see what the policy covers. It is not legal advice. A policy drafted in Luna is your firm's draft to review, edit and adopt.