Code of ethics · Rule 204A-1

Personal trading compliance software and employee trading compliance software for RIAs, funds and broker-dealers

Personal trading compliance software collects employee holdings and trades from brokerage feeds, runs pre-clearance against restricted lists and blackout periods, and files the quarterly reports Rule 204A-1 requires within 30 days of quarter end. StarCompliance, ComplySci, MyComplianceOffice and Smartria all sell it, and none of them publishes a price.

10 days initial holdings 30 days after quarter end $1.2M SEC penalty, June 2026

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SOC 2 ISO 27001 GDPR HIPAA AML / KYC SOX PCI DSS

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Investment adviser (RIA), US · first rows of a real scan

§ 01 Written AML program with a named officer 31 CFR 1020/1022; BSA
§ 02 KYC / Customer identification program 31 CFR 1020.220
§ 03 Customer due diligence and beneficial ownership FinCEN CDD Rule
§ 04 Transaction monitoring and SAR filing 31 CFR 1020.320

§ 02

What the software has to deliver

Employee trading compliance software is bought for six deadlines and limits

Every feature list in this category traces back to a handful of rules. If a tool cannot prove each of these on demand for every access person, it is not doing the job an examiner will test.

10 days

Initial holdings report after someone becomes an access person, data no older than 45 days (Rule 204A-1)

30 days

Quarterly transaction report after each calendar quarter ends (Rule 204A-1 and Rule 17j-1)

12 months

Annual holdings report on a date the firm picks, data no older than 45 days

Pre-approval

Before any IPO or limited offering purchase by an access person

$350 / $150

Pay-to-play de minimis per official per election, two-year time-out above it (Rule 206(4)-5)

30 days

FINRA Rule 3210 written consent for an outside account held when a rep joins

Portfolio manager at a trading desk submitting a pre-clearance request from his phone — Pre-clearance only works if it is faster than the trade. The rule demands it for IPOs and limited offerings; most codes of ethics extend it to every reportable security.

§ 03

The vendors

Personal trading compliance software compared on pricing model and broker coverage

We checked each vendor's site, AWS Marketplace, the UK G-Cloud catalogue, US federal award records and Vendr. No vendor in this category publishes a figure in any of them. What can be compared is how each one prices and how it gets the trades in.

Personal trading compliance vendors compared
Vendor	How trades come in	Public price evidence	Best fit
ComplySci (COMPLY)	Direct broker feeds from more than 200 brokerage firms (COMPLY, 2022)	Quoted. Vendr has a page with no recorded contracts	RIAs and asset managers that want the COMPLY bundle
StarCompliance	About 100 direct feeds plus hundreds more through clearinghouses, refreshed every 24 hours	Quoted. Vendr records only two purchases, too few to benchmark	Larger firms with global staff and complex restricted lists
MyComplianceOffice (MCO)	Direct feeds, OCR capture of statements and confirms, manual upload; no published feed count	Quoted. No recorded contracts on Vendr	Broker-dealers and banks wanting trading, OBAs and attestations in one suite
Smartria	Trades from "thousands of brokers and custodians"	"Customized pricing" by firm size and complexity	Small and mid-size RIAs
RIA in a Box (COMPLY)	Reconciles employee trades against restricted lists and client trades	Monthly fee per user; SEI clients get 10% off and a waived implementation fee	Small RIAs buying compliance as a service
ComplianceOfficer	Does not collect trades	$149 a month or $894 a year, published	Tracking the SEC and FINRA rule changes behind your code of ethics

Feed coverage is the honest tiebreaker. A firm whose staff hold accounts at a dozen mainstream US brokerages will be covered by any of them. A firm with staff at small regional brokers, or abroad, should send each vendor its actual list of brokers and ask which arrive by direct feed, which by clearinghouse and which by statement upload, because the last group is manual work every quarter.

The feed itself can carry a cost. Schwab's own paper on employee trading feeds describes direct feeds as "typically free, unlimited feeds" and indirect feeds as an annual recurring cost that depends on the number of accounts. Ask each vendor whether feed fees are inside the quote.

§ 04

Getting a quote

How much personal trading compliance software costs and what moves the quote

With no list prices, the quote is built from four numbers you control. Have them ready before the first call and you can compare three vendors on the same basis in a week.

Covered people

Access persons, not headcount. If advice is your primary business, every director, officer and partner counts.

Accounts and brokers

How many reportable accounts, at which firms. This decides feed fees and manual upload work.

Modules

Trading only, or also gifts and entertainment, political contributions, outside activities and attestations.

Term

Multi-year terms usually buy the rate. Ask for a renewal cap and the right to reduce seats.

The covered-person count is where firms overpay and underreport at the same time. The SEC order discussed below found that the firm's chief investment officer "should have been identified as an access person from June 2019 onwards, but was not." Count from the rule's definition, not from whoever currently has a login. For the archive and supervision side of the same budget, see Smarsh pricing, and for the full RIA stack, RIA in a Box cost.

Compliance officer reviewing a quarterly personal securities transaction report at her desk

§ 05

What examiners find

Code of ethics software exists because of orders like this one

On June 8, 2026 the SEC settled with Foundations Investment Advisors and its chief investment officer (Advisers Act Release No. 6970). The CIO bought an ETF the firm recommended to clients on 87 days without pre-clearing a single trade, while the firm's code required written pre-clearance from the chief compliance officer. The order found violations including Rule 204A-1. The firm paid a $1,200,000 civil penalty and the CIO $354,675, each on top of disgorgement.

Two lessons carry over to any buyer. Pre-clearance has to be enforced by a system, not a form, because the SEC charges the firm for failing to enforce its own code. And the system is only as good as its list of access persons, which is a judgment the software cannot make for you. A separate SEC order (IA-6896) barred a former CCO from compliance roles for three years for altering pre-clearance forms handed to examiners, which is the risk a paper process invites.

§ 06

Where ComplianceOfficer fits

Buy a trading tool for the feeds and keep the rules behind your code current

Buy a personal trading tool for

Feeds, pre-clearance and quarterly reports

Holdings and trades from brokers, restricted lists, blackout periods and the reports each access person files. ComplySci, StarCompliance, MCO and Smartria do this. We do not.

Buy ComplianceOfficer for

Knowing when the rules under your code change

The SEC and FINRA sources checked daily against your adviser or broker-dealer register, a status on every obligation, a policy update drafted for each gap you mark, and a dated trail for your annual review. FINRA Rule 3290, approved in September 2026 with no effective date yet, is exactly the kind of change it is built to catch.

Get started for $149 a month RIA compliance software Broker-dealer compliance software Hedge fund compliance software

§ 07

Questions buyers ask

How much does personal trading compliance software cost?

None of the main vendors publishes a price. StarCompliance, ComplySci, MyComplianceOffice and Smartria all quote, usually by the number of covered employees, and RIA in a Box bills a monthly fee per user according to a custodian partner sheet. Brokerage feeds can add cost: Schwab describes direct feeds as typically free and indirect feeds as an annual charge that varies with the number of accounts.

Who is an access person under Rule 204A-1?

An access person is a supervised person who has access to nonpublic information about clients' securities transactions or the holdings of a reportable fund, or who is involved in making securities recommendations to clients. If giving investment advice is the firm's primary business, all directors, officers and partners are presumed to be access persons.

When are quarterly transaction reports due under Rule 204A-1?

No later than 30 days after the end of each calendar quarter. That makes the dates January 30, April 30, July 30 and October 30. A firm can skip a separate report where it already receives duplicate broker confirmations or statements covering the same information within that 30-day window.

Do RIAs have to pre-clear employee trades?

Rule 204A-1 requires pre-approval only before an access person buys a security in an initial public offering or a limited offering, such as a private placement. Most firms go further and require pre-clearance of all reportable trades in their code of ethics, and once the code says so, the SEC treats failure to enforce it as a violation.

What is the deadline for an initial holdings report?

No later than 10 days after the person becomes an access person, with the information current as of a date no more than 45 days before that day. Annual holdings reports follow at least once every 12 months on a date the firm selects, again with information no more than 45 days old.

Does FINRA Rule 3290 replace Rules 3270 and 3280?

Yes. The SEC approved FINRA Rule 3290 on outside activities in Release No. 34-106381 on September 15, 2026, replacing Rule 3270 on outside business activities and Rule 3280 on private securities transactions. FINRA has not yet set an effective date, so firms keep following 3270 and 3280 until it announces one.

See which SEC and FINRA rules on your register moved this year

One register of the rules that apply to your firm, checked daily, with a policy update drafted for each gap you mark. $149 a month for one owner, $298 for up to three people, month to month. Compare every plan on pricing.

Start for $149 a month Run the compliance scan

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