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Sorry if this is too OT; a search didn't come up with anything.

An interesting memo came around at work yesterday, requiring all employees to not only disclose all securities accounts in which we have investment authority, but also to have copies of monthly statements AND all trade confirms mailed to HR.

Has anyone had any experience with this? My first reaction was that it's incredibly intrusive. The company is a financing & leasing subsidiary of a major international bank, and the policy is ostensibly to ward off any insider trading based on, I guess, deals we might be doing.

More curious is the statement "Personal investments should be made with the emphasis on investment, as opposed to speculation. Therefore, short-term, "in-and-out" or highly leveraged trading should generally be avoided." I'm wondering who is going to define investment vs. speculation. Does this mean I can't trade on margin, or use options, or even LEAPS? I don't, but could I if I wanted to?

There are accounts that are exempt from disclosure -- it specifically excludes "401(k) and other retirement accounts" and "open-ended mutual fund accounts", though the accompanying memo from the head of the Legal Dept. says that self-directed IRAs are reportable. This seems contrary to what's actually stated in the policy.

Anyway, I won't go into more detail unless someone asks. Anyone out there seen this kind of thing before? Any links to previous discussions would be greatly appreciated. Also, if another board would be a more appropriate venue, by all means point me in that direction.


p.s. cross-posted on the 401(k) board
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