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And personal trades are usually required to be cleared by a company's compliance department.
The document was a memorandum detailing the manager's personal trades, as required under the firm's ethics code.
Officials at Putnam Investments said yesterday that they fired four fund managers for making improper personal trades three years ago in shares of the funds they managed.
IN its reprimand, Putnam restricted Mr. O'Neill to 20 personal trades for 30 days and directed him to help rewrite Putnam's ethics code.
In one case, a portfolio manager was found to have created a false document to conceal improper personal trades, according to a former employee.
WHATEVER further details emerge about personal trades made by Philipp Hildebrand, ex-president of the Swiss National Bank (SNB), who resigned on January 9th, the central bank itself is now under huge pressure to restore its credibility.
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The letters seek documents like personal trading records as well as e-mails and instant messages.
And personal trading should be consistent with investment recommendations, the rules say.
Mr. Goel testified that Mr. Rajaratnam had bought Hilton shares in Mr. Goel's personal trading account.
"This was Mr. Hertz's personal account, his personal trading," said Rafi Reguer, Track Data's marketing director.
The company said late yesterday that Mr. Strong would reimburse shareholders for any losses they suffered from his personal trading.
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