So, there have been some new regulations passed recently that have been making my life difficult.
The specific one I have a bee in my bonnet about today is one that pertains to some new rules regarding the Investment Advisors Act of 1940. This requires employees defines as "Access Persons" to file all sorts of detailed reports on all their holdings and financial transactions. I'd don't have a problem with that part. The part I have a problem with is that I also have do it for members of my immediate family in the same household. That I have a problem with because it makes some pretty bad assumptions and invades the privacy of a man whose only crime was marrying me.
I work for a company that provides financial data on bonds and other fixed income securities. If you're reading this you probably already know that I'm a programmer. Mostly what I do at my job is deal with programs that load various data files from various sources into our database so that we can put that information up on our website in human readable format. I don't actually know anything about investing beyond the fact that mutual funds seem to me to give the most return for the least amount of effort on my part. On the other hand, since my compnay is classifies as an Investment Advisor, and since I have access to our customers portfolios by virtue of how things are set up here, I'm an Access Person. The fact that a file full of cusips and other numbers tells me nothing is beside the point.
Now, I don't have a problem reporting my holdings and transactions. I only have mutual funds, and its been years since I made a transaction that wasn't a voluntary contribution to my 401k. I'm also aware that if I were a much more devious, financially savvy, smarter, and a whole lot more motivated, I might somehow be able to glean some sort of insider information off this stuff. Maybe. So telling my company what I'm up to so they can report it to the SEC is possibly justified and not such a big deal.
The problem I have is that now they want me to spy on my husband as well. I think that's going a bit to far. Sure, lots of couples share finances and information, and one member of the couple could pass information to the other for gain. On the other hand, that's not all couples and that's certainly not us. As it happens, Warren and I have completely seperate accounts and finances. The house is in his name, we don't have any joint accounts, etc. I currently have no clue what sort of investments he has. I'm not particularly interested. We're not one of those couples who feels the need to share absolutely everything with each other. We prefer to respect each other's privacy, and it works for us.
Unfortunately the SEC is coming along and saying that essentially I'm not allowed to respect his privacy anymore. Here they are telling me that I have to poke into his private accounts and then report that information to the company I work for, a company that he has absolutely nothing to do with. I've had a chat with our legal department about this, and they don't think there's any way around it. They did offer to let him report his information directly to them if he didn't want to share this information with me, but as Warren pointed out, he'd much rather tell me than the company I happen to work for.
I suppose the whole thing doesn't surprise me too much. I mean it makes perfetc sense. Some rich guys went a did something that was already clearly illegal (market timing, insider trading), and the reaction is to pass new rules that infringe on the privacy of a whole bunch of people. Its what I've come to expect of our government.