# Personal Trading Report: [Access person name], [Reporting period] > Holdings report, quarterly transaction report and pre-clearance > request for an access person of an SEC-registered investment adviser. > The content and timing follow SEC Rule 204A-1(b) and (c) under the > Investment Advisers Act of 1940 (17 CFR 275.204A-1, as amended through > 81 FR 83554, 2016), and the records follow Rule 204-2(a)(13). It is the > filing form that sits under the firm's Code of Ethics > (`compliance/investment-adviser-code-of-ethics`). The example firm, > Kestrel Bay Capital, and the example issuers are fictional. Replace > every `[bracketed]` value and every row marked *Example*. Obtain the > rule for the normative text. This is a document format, not legal, > compliance or investment advice. ## Document control | Field | Value | |---|---| | Document ID | [PTR-2026Q3-JDOE] | | Firm | [Kestrel Bay Capital LLC] *(Example)* | | Version | [1.0] | | Status | [Draft / Submitted / Under review / Reviewed, no exceptions / Reviewed, exceptions raised] | | Owner | [@access-person] | | Approvers/reviewers | [@compliance-reviewer], [@chief-compliance-officer] | | Date received by compliance | YYYY-MM-DD | | Last updated | YYYY-MM-DD | | Classification | [Confidential: personal data] | | Retention | Five years from the end of the fiscal year of the last entry, first two years in an appropriate office (Rule 204-2(e)(1)) | | Code of ethics version applied | [COE-001 v1.0] | ### Approvals | Role | Name | Decision | Date | |---|---|---|---| | Access person (submitter) | [@name] | [Certified] | YYYY-MM-DD | | Compliance reviewer | [@name] | [No exceptions / Exceptions logged] | YYYY-MM-DD | | Chief Compliance Officer (exceptions or CCO's own report reviewed by alternate) | [@name] | [Decision] | YYYY-MM-DD | ### Revision history | Version | Date | Author | Change | |---|---|---|---| | 1.0 | YYYY-MM-DD | [@author] | Submitted | | 1.1 | YYYY-MM-DD | [@author] | Corrected after compliance query (late correction noted in section 9) | ## Contents - [1. Reporter details](#1-reporter-details) - [2. Report type and period](#2-report-type-and-period) - [3. Holdings of reportable securities](#3-holdings-of-reportable-securities) - [4. Accounts holding securities](#4-accounts-holding-securities) - [5. Quarterly transactions](#5-quarterly-transactions) - [6. Pre-clearance requests](#6-pre-clearance-requests) - [7. Exempt securities, accounts and transactions](#7-exempt-securities-accounts-and-transactions) - [8. Other disclosures](#8-other-disclosures) - [9. Compliance review](#9-compliance-review) - [10. Certification](#10-certification) - [Glossary and references](#glossary-and-references) - [Standard and licence note](#standard-and-licence-note) ## 1. Reporter details | Field | Entry | |---|---| | Full name | [Name] | | Employee ID | [ID] | | Role and team | [Role, team] | | Date became an access person | YYYY-MM-DD | | Covers issuers or strategies | [Sectors or strategies covered, used for blackout checks] | | Household members whose accounts are included | [Names and relationship] | | Trusts, companies or partnerships in which the reporter has a beneficial interest | [Names] | Name every person and entity whose holdings are included. If a family member lives with you but you believe you have no beneficial interest in their accounts, list them anyway and explain in section 7; the Chief Compliance Officer (CCO) decides whether reporting can be excluded. ## 2. Report type and period | Report type | Tick | Period or as-of date | Due date | Date submitted | |---|---|---|---|---| | Initial holdings report | [ ] | Data as of YYYY-MM-DD | 10 days after becoming access person | YYYY-MM-DD | | Annual holdings report | [ ] | Data as of YYYY-MM-DD | [Firm date, for example 31 January] | YYYY-MM-DD | | Quarterly transaction report | [ ] | Quarter YYYY-Qn | 30 days after quarter end | YYYY-MM-DD | | Combined annual holdings and Q4 transactions | [ ] | Year YYYY | [Firm date, no later than 30 January] | YYYY-MM-DD | Quarter due dates for a calendar year, each 30 days after quarter end: | Quarter | Quarter end | Report due | |---|---|---| | Q1 | 31 March | 30 April | | Q2 | 30 June | 30 July | | Q3 | 30 September | 30 October | | Q4 | 31 December | 30 January | Holdings data must be current as of a date no more than 45 days before the date you became an access person (initial report) or before the date you submit (annual report). A brokerage statement dated more than 45 days earlier is not acceptable; download a current position report instead. ## 3. Holdings of reportable securities List every reportable security in which you have direct or indirect beneficial ownership on the as-of date in section 2. Report positions in any account listed in section 4 and any securities held outside an account. Use the security's legal name and type. Give the ticker for listed securities and the CUSIP or ISIN where one exists. For bonds, give the principal amount; for shares and fund units, give the number held. | Holding ID | Title of security | Type | Ticker / CUSIP / ISIN | Number of shares or units | Principal amount | Account (section 4) | Owner | |---|---|---|---|---|---|---|---| | HLD-001 *(Example)* | Halvard Tools ordinary shares (fictional issuer, listed in Europe, traded in EUR) | Common stock | [HLVD] / [ISIN] | 1,200 | Not applicable | ACC-001 | Reporter | | HLD-002 *(Example)* | [Broad market equity ETF] | Exchange-traded fund | [Ticker] | 350 | Not applicable | ACC-001 | Reporter | | HLD-003 *(Example)* | [Corporate bond 4.25% due 2031] | Corporate bond | [CUSIP] | Not applicable | USD 25,000 | ACC-002 | Spouse | | HLD-004 *(Example)* | [Private company] Series A preferred | Private placement | None | 5,000 | Not applicable | Held directly | Reporter | | HLD-005 *(Example)* | Kestrel Bay Income Fund shares (reportable fund) | Registered closed-end fund advised by the firm | [Ticker] | 410.237 | Not applicable | ACC-003 | Reporter | If you hold no reportable securities, write "No reportable securities held as of YYYY-MM-DD" and still complete section 4. A report may state that it is not an admission that you have beneficial ownership of any security listed (Rule 204A-1(e)(3)). ## 4. Accounts holding securities | Account ID | Institution (broker, dealer or bank) | Account title and owner | Account number (last 4 digits) | Type | Discretion | Feed to compliance | Opened | |---|---|---|---|---|---|---|---| | ACC-001 *(Example)* | [Broker A] | Reporter, individual | [1234] | Brokerage | Self-directed | Yes | YYYY-MM-DD | | ACC-002 *(Example)* | [Broker B] | Spouse, individual | [5678] | Brokerage | Self-directed | Yes | YYYY-MM-DD | | ACC-003 *(Example)* | [Fund transfer agent] | Reporter, individual | [9012] | Fund account | Self-directed | Statements | YYYY-MM-DD | | ACC-004 *(Example)* | [Bank C wealth manager] | Family trust | [3456] | Managed account | Full discretion, no influence (see section 7) | Annual letter | YYYY-MM-DD | | ACC-005 *(Example)* | [Employer plan provider] | Reporter, retirement plan | [7890] | Retirement plan, open-end funds only | Self-directed | No | YYYY-MM-DD | New accounts must be notified to compliance before the first trade, and closed accounts must be shown with their closing date in the next report. Do not give full account numbers in this form if the firm collects them through a secure broker connection. How to find every account. Work from documents rather than memory. Go through the last year of tax forms (consolidated broker forms and bank interest statements list every institution that paid you income), the login list of your financial apps, employer benefit portals, and the statements of each household member named in section 1. Include accounts that hold only cash or exempt funds today, because they can buy reportable securities tomorrow; trading apps and crypto exchanges; the brokerage window inside a retirement plan; custodial accounts for children; and accounts of a trust or company you control. If you are a trustee or executor for someone outside your household, list the account and ask the CCO whether you have beneficial ownership; the answer depends on whether you or your family can benefit. Common errors the reviewer will look for: an account that appears in the broker feed but not in this table; an account closed without a closing date; an account shown as "no discretion" when the reporter gives instructions; and a spouse's employer plan that offers a self-directed brokerage window. ## 5. Quarterly transactions List every transaction in a reportable security in which you had, or acquired through the transaction, direct or indirect beneficial ownership during the quarter. Include sales and purchases in every account in section 4 except those exempt under section 7, and include transactions that were not trades in the ordinary sense: securities received or given as gifts, inherited positions, exercises of options or rights, conversions and tender offer elections. | Txn ID | Trade date | Title of security | Ticker / CUSIP | Interest rate and maturity | Nature | Shares or units | Principal amount | Price | Broker, dealer or bank | Pre-clearance ID | |---|---|---|---|---|---|---|---|---|---|---| | TXN-001 *(Example)* | 2026-07-14 | Halvard Tools ordinary shares | [HLVD] | Not applicable | Purchase | 200 | Not applicable | EUR 42.00 | [Broker A] | PCR-014 | | TXN-002 *(Example)* | 2026-08-21 | [Corporate bond] | [CUSIP] | 4.25%, 2031-06-15 | Sale | Not applicable | USD 10,000 | 98.75 (percent of par) | [Broker B] | PCR-019 | | TXN-003 *(Example)* | 2026-09-02 | [Broad market equity ETF] | [Ticker] | Not applicable | Gift received from parent | 50 | Not applicable | Not applicable (gift) | [Broker A] | Not required (gift received, reported) | Value check for the examples: TXN-001 cost 200 x EUR 42.00 = EUR 8,400 before commissions (report the price in the currency of execution; do not convert). TXN-002 proceeds were USD 10,000 x 98.75% = USD 9,875 before accrued interest and commissions. ### 5.1 Situations that often cause errors Joint accounts. Report every account you hold jointly with another person, even if the other person makes all decisions. If you believe you have no influence or control, request an exemption under section 7 rather than leaving the account out. Corporate actions. Mandatory events such as stock splits, spin-offs and mergers where you made no choice are usually not trades that need pre-clearance, but the resulting positions must appear in the next holdings report. Voluntary events where you chose an outcome, such as a tender offer, a rights issue or an election between cash and shares, are transactions to report and, under most codes, to pre-clear. Gifts and inheritances. Securities you receive or give are changes in beneficial ownership. Report them in the quarter they occur with the nature "gift received", "gift given" or "inheritance" and leave the price blank where none applies. Options and derivatives. Writing an option counts as a purchase or sale under Rule 204A-1(e)(8). Report the option itself when written or bought, and report the underlying security if the option is exercised or assigned. Derivatives that give exposure to a reportable security, such as single-stock contracts for difference, are reported under most codes even where the instrument itself is held outside the US. Digital assets. Whether a given crypto asset is a security is a legal question that depends on the facts. Follow the firm's code: many firms require pre-clearance and reporting of all digital assets regardless of their legal status, and list the wallets or exchange accounts in section 4. Funds advised by the firm. Shares of mutual funds the firm or an affiliate advises are reportable funds, so purchases, sales and exchanges in them are reported even though most open-end funds are excluded. Check the list of reportable funds that compliance publishes. If there were no reportable transactions in the quarter, write "No reportable transactions in quarter YYYY-Qn" and sign the certification. If all transactions are already in broker confirmations or statements the firm receives within 30 days after quarter end, write "All transactions are in broker data received by compliance for accounts [ACC-001, ACC-002]" and list any transaction that is not. ## 6. Pre-clearance requests ### 6.1 Request form | Field | Entry | |---|---| | Request ID | [PCR-NNN] | | Date and time of request | YYYY-MM-DD hh:mm | | Security and identifier | [Title, ticker, CUSIP or ISIN] | | Direction | [Buy / Sell / Short / Option write / Other] | | Quantity or principal | [Amount] | | Order type | [Market / Limit at price] | | Account | [ACC-NNN] | | Initial public offering or limited offering | [Yes, type / No] | | Covered in my research or managed in my portfolios | [Yes / No] | | Last purchase or sale of this security (for holding period) | YYYY-MM-DD | Requester confirmations (tick each): - [ ] I do not have material non-public information about this issuer. - [ ] I am not aware of any pending or planned client order or recommendation in this security. - [ ] The trade is not part of a pattern of short-term trading and respects the minimum holding period in the code. - [ ] For an IPO or limited offering, the opportunity was not offered to me because of my position at the firm, or I have described the relationship below. ### 6.2 Decision record | Request ID | Security | Direction | Checks run | Decision | Reasons | Valid until | Decided by | |---|---|---|---|---|---|---|---| | PCR-014 *(Example)* | Halvard Tools | Buy 200 | Restricted list clear; no client order open today (PTR-002); reporter does not cover the issuer, so PTR-003 does not apply; no client trade in prior 7 days in any case | Approved | No conflict found | 2026-07-15 close | [@compliance-analyst] | | PCR-017 *(Example)* | [Listed issuer] | Buy 500 | Issuer on restricted list | Denied | Restricted; reason not disclosed to requester | Not applicable | [@compliance-analyst] | | PCR-019 *(Example)* | [Corporate bond] | Sell USD 10,000 | Held 14 months (holding period met); firm sold the same bond for clients on 2026-08-18, all client orders completed, none open today, so the same-day blackout (PTR-002) is clear; reporter is an operations analyst, not a portfolio manager or analyst for this issuer, so the 7-day blackout (PTR-003) does not apply | Approved with condition: no further trade in the issuer until the next quarter | Same direction as clients and after their orders completed; no advantage over clients | 2026-08-24 close (request made Friday 2026-08-21; valid to end of next business day) | [@cco] | | PCR-021 *(Example)* | [Private company] Series B | Buy USD 25,000 | Limited offering under Rule 506; issuer not held by clients; offered through a friend unrelated to firm business | Approved | No client opportunity diverted; no relationship with firm | 2026-09-30 | [@cco] | How pre-clearance decisions are made. Most requests are decided by the compliance system against four lists: the restricted list (PTR-001), the day's client orders and open orders (PTR-002), the client blotter for the blackout window that applies to the requester's role (PTR-003 and PTR-004 for investment and research staff), and the requester's own last trade in the security for the holding period. A request is routed to a person when any check flags, when the requester covers the issuer, when the security is an IPO or a limited offering (Rule 204A-1(c) requires a documented decision), or when the size is large relative to the market in the security. The reviewer records the facts relied on, not only the outcome, because the reasons are part of the record under Rule 204-2(a)(13)(iii) for IPOs and limited offerings and are good practice for every other decision. A denial is not an accusation. Reasons for a restricted-list denial are never explained to the requester, since the explanation would itself disclose confidential information. Approvals lapse at the end of the next business day; a limit order still open at that point must be cancelled and a new request made. Approval also lapses at once if the requester learns of a client order or receives material non-public information before the trade is executed. ```mermaid sequenceDiagram participant AP as Access person participant CS as Compliance system participant CO as Compliance reviewer AP->>CS: Submit pre-clearance request (PCR) CS->>CS: Check restricted list, open client orders, blackout, holding period alt Automatic checks pass and not IPO or limited offering CS-->>AP: Approved, valid to end of next business day else Flag raised or IPO or limited offering CS->>CO: Route for manual review CO-->>AP: Approve, approve with conditions, or deny, with reasons recorded end AP->>AP: Trade inside validity window CS->>CO: Broker feed reconciled against approval ``` ## 7. Exempt securities, accounts and transactions The following are not reportable securities under Rule 204A-1(e)(10), so they are not listed in section 3 or section 5: direct obligations of the US government; bankers' acceptances, bank certificates of deposit, commercial paper and high quality short-term debt including repurchase agreements; shares of money market funds; shares of open-end funds other than reportable funds; and units of unit investment trusts that invest only in open-end funds that are not reportable funds. Funds advised by the firm or an affiliate are reportable funds and must be listed. Accounts or transactions excluded on another basis: Evidence for a no-influence or control exemption. Rule 204A-1(b)(3)(i) excludes reports for accounts over which the access person has no direct or indirect influence or control, but the SEC staff has said that a discretionary arrangement alone is not enough. Before approving EXM-001, the CCO should hold: the investment management agreement showing full discretion; a written statement from the manager that the access person has not suggested, directed or been consulted on any trade; a certification from the access person to the same effect, renewed each year; and, where practicable, the right to ask for account statements to test the claim. Reconsider the exemption if the access person is related to the manager, holds a power to change the investment guidelines, or is copied on trade proposals. Record the review in the exemption register and repeat it at least annually. | Exemption ID | Account or transaction | Basis | Evidence | CCO decision | |---|---|---|---|---| | EXM-001 *(Example)* | ACC-004 family trust managed account | No direct or indirect influence or control (Rule 204A-1(b)(3)(i)) | Manager's annual letter confirming no instructions; reporter's certification | Approved YYYY-MM-DD; reviewed annually | | EXM-002 *(Example)* | Monthly purchase of [ETF] in ACC-001 | Automatic investment plan: no quarterly transaction report needed (Rule 204A-1(b)(3)(ii)); holdings still reported | Plan schedule on file | Approved YYYY-MM-DD | | EXM-003 *(Example)* | ACC-005 retirement plan | Holds only open-end funds that are not reportable funds | Plan fund list | Account listed; no transactions reported | ## 8. Other disclosures | Topic | Question | Answer | |---|---|---| | Outside business activities | List every outside role, paid or unpaid, held during the period | [None / list with OBA IDs] | | Gifts and entertainment | Were all gifts and entertainment above the code limits logged? | [Yes / No, explain] | | Political contributions | Any contribution to a US state or local official, candidate, party or political action committee? | [None / list with pre-clearance IDs] | | Material non-public information | Did you receive any information you believe may be inside information and not report it? | [No / explain] | | Investment clubs | Are you a member of any investment club? | [No / name and approval ID] | | Violations | Are you aware of any violation of the code by you or others not yet reported? | [No / report now to the CCO] | ## 9. Compliance review The reviewer completes this section within the period set by the code (for example 15 business days after receipt). The review has two layers. The first checks completeness and timeliness: was the report on time, is every account present, does the holdings data fall within the 45-day window and does every transaction match the broker data. The second looks at substance: whether any personal trade could have taken advantage of client activity, research or inside information. For the second layer, compare each personal trade with client orders in the same issuer over a window before and after the trade, and look for patterns across quarters, not only single trades. Document a conclusion even when nothing was found, because an examiner will ask how the firm reviewed the report, not only whether it was filed. When a test fails, open an exception record, tell the reporter what is missing or wrong, and set a date to correct it. A corrected report keeps the original on file and adds a new version in the revision history, so the record shows both the late correction and the original content. | Test ID | Test | Result | Notes | |---|---|---|---| | TST-001 | Submitted on time (initial 10 days, quarterly 30 days, annual on firm date) | [Pass / Fail] | [Days late] | | TST-002 | Holdings data within 45 days of required date | [Pass / Fail] | [Statement date] | | TST-003 | All accounts match broker feeds and prior reports | [Pass / Fail] | [Differences] | | TST-004 | Every transaction has valid pre-clearance (where required) | [Pass / Fail] | [Txn IDs without approval] | | TST-005 | No trade in a restricted issuer or inside a blackout window | [Pass / Fail] | [Details] | | TST-006 | Minimum holding period respected | [Pass / Fail] | [Details] | | TST-007 | IPO and limited offering acquisitions all pre-approved | [Pass / Fail] | [Details] | | TST-008 | Pattern review: personal trades compared with client trades over [30] days | [Pass / Fail] | [Observations] | Example review outcome *(Example)*: TST-001 to TST-007 passed. TST-008 noted that TXN-002 sold the same bond three days after client sales; the trade was pre-cleared (PCR-019), the reporter is not investment staff covering the issuer (so PTR-003 does not apply), no client order was open on the trade date, and the sale was in the same direction as clients and after their orders completed, so no exception was raised. Had the reporter been a portfolio manager or analyst covering the issuer, the trade would have breached the 7-day blackout and been reversed or the profit disgorged under the code. | Exception ID | Test | Finding | Action | Sanction level (code section 12) | Closed | |---|---|---|---|---|---| | EXP-001 *(Example)* | TST-001 | Q2 report submitted 3 days late | Reminder issued; calendar alert set | 1 | YYYY-MM-DD | ## 10. Certification I certify that this report is complete and accurate. It includes every reportable security and every account holding securities in which I have direct or indirect beneficial ownership, including accounts of household members, for the report type and period stated in section 2. I have pre-cleared every transaction that the Code of Ethics requires to be pre-cleared and obtained approval before acquiring any security in an initial public offering or limited offering. I understand that this report may be reviewed against broker data and client trading, and that false or incomplete reporting is a violation of the code. This report is not an admission that I have beneficial ownership of any security listed. | Field | Entry | |---|---| | Signature | [________________] | | Name | [Full name] | | Date submitted | YYYY-MM-DD | ## Glossary and references | Term | Meaning | |---|---| | Access person | Supervised person with access to non-public client trading, holdings or recommendation information (Rule 204A-1(e)(1)) | | Beneficial ownership | Direct or indirect interest, interpreted as under Exchange Act Rule 16a-1(a)(2) | | CUSIP / ISIN | Security identifiers used in North America and internationally | | Initial public offering | First registered offering by an issuer not previously reporting under the Exchange Act | | Limited offering | Offering exempt under Securities Act Section 4(a)(2), 4(a)(5), Rule 504 or Rule 506 | | Pre-clearance | Compliance approval obtained before a personal trade | | Reportable fund | Registered fund the firm advises or sub-advises, or whose adviser or principal underwriter controls the firm, is controlled by it or is under common control with it (Rule 204A-1(e)(9)) | | Reportable security | Any security except the exclusions in Rule 204A-1(e)(10) | | Restricted list | Confidential list of issuers in which personal trading is prohibited | References (check the current official versions): - SEC Rule 204A-1, 17 CFR 275.204A-1, paragraphs (b), (c) and (e) (eCFR). - SEC Rule 204-2, 17 CFR 275.204-2, paragraphs (a)(13) and (e)(1). - Exchange Act Rule 16a-1(a)(2), 17 CFR 240.16a-1 (beneficial ownership). - SEC Rule 17j-1 under the Investment Company Act, for access persons of registered funds. - Related templates: Code of Ethics (`compliance/investment-adviser-code-of-ethics`), Annual Compliance Review (`compliance/annual-compliance-review`), Conflicts of Interest Register (`compliance/conflicts-of-interest-register`). ## Standard and licence note Based on SEC Rules 204A-1 and 204-2 under the Investment Advisers Act of 1940 as published in the electronic Code of Federal Regulations (US federal works, public domain). Rule paragraph numbers are cited and the requirements are described in original wording; no regulatory text is reproduced. Kestrel Bay Capital, Halvard Tools and every example row are fictional. Check the current rule text on eCFR and your firm's code of ethics before use. This is a document format, not legal, compliance or investment advice. Template licence: MIT.