Code of Ethics and Personal Trading Pre-Clearance Log

Use it for access persons, supervised employees, and anyone covered by your firm's Code of Ethics or personal trading policy. It is especially useful for compliance teams that need a consistent record of requests, approvals, and post-trade follow-up. If your policy only requires pre-clearance for certain securities or account types, the template can be narrowed with conditional logic.

This template is built for proposed personal securities transactions, including stock, ETF, mutual fund, and other reportable securities if your policy covers them. It captures the security details, transaction type, trade date, quantity, estimated value, and brokerage account last four digits. If your firm excludes certain holdings or account types, you can remove those fields or make them conditional.

Employees should submit it before each trade that requires pre-clearance under the firm's policy. Some firms also use it for recurring review of outside accounts or for periodic attestations, but this template is focused on individual trade requests. If you need annual holdings or quarterly transaction reporting, use a separate disclosure form or add a linked follow-up workflow.

A compliance officer, ethics officer, or designated reviewer should record the decision. The approval section captures the decision date, approver name, any conditions, and whether post-trade confirmation is required. That creates an audit trail that shows not just the outcome, but the basis for the decision and any exceptions.

The review section prompts the reviewer to document whether the security is on a restricted list, whether a blackout period applies, and whether the employee has access to material nonpublic information. Those fields support a consistent decision process and reduce the chance of approving a trade without checking policy triggers. If your firm uses a watch list or client-related restrictions, those can be added as conditional fields.

For a personal trading pre-clearance log, anonymous submission is usually not appropriate because the request must be tied to a specific employee and account for review and recordkeeping. The template includes an anonymous submission control because some organizations reuse the same form framework for other compliance workflows. For this use case, keep identity fields required and disable anonymous mode.

Common issues include leaving out the brokerage account identifier, failing to record the decision date, and approving a trade without documenting restricted list or blackout checks. Another frequent problem is collecting too much information, such as unnecessary personal data, instead of following data minimization. Clear required fields and conditional logic help keep the form usable and defensible.

Email-only approvals are harder to search, harder to audit, and easier to miss when post-trade confirmation is due. This template creates a structured record of the request, the review factors, the decision, and any conditions in one place. It is better suited to repeatable compliance workflows and cleaner audit trails.

It can be paired with compliance case management, document storage, HR systems, or brokerage account review workflows. Common integrations include notifications to approvers, task creation for post-trade follow-up, and export to an audit archive. If you use a restricted list or watch list system, the review fields can be mapped to that process.