RIA Glossary / Firm Roles & Structure

Access Person

Quick Answer
An access person is a supervised person who has access to nonpublic information about client securities transactions or holdings, or who is involved in making investment recommendations. Access persons face additional personal trading disclosure and reporting requirements under the SEC’s Code of Ethics rule.
Reviewed by Sam Carter, Director of Registration Services
Last reviewed September 18, 2026

Who Is an “Access Person” at an RIA?

Because access persons can see what trades are being made or recommended before the public does, the rule requires them to report their personal securities holdings and transactions on a periodic basis — typically initial holdings reports, quarterly transaction reports, and annual holdings reports. At many advisory firms, most or all supervised persons qualify as access persons given the small size of the team and broad visibility into client activity.

The firm’s code of ethics must specify the process for collecting, reviewing, and retaining these reports, and the CCO or a designated reviewer is expected to actually review them for red flags like trading ahead of client transactions.

Why it Matters

Personal trading conflicts are a core focus of the Code of Ethics rule, and examiners routinely check whether access person reports are being collected and genuinely reviewed — not just filed away.

Frequently Asked Questions

Is every employee at a small RIA an access person?

Often yes, since small firm structures frequently give most staff visibility into client holdings and trading activity.

What has to be reported?

Typically personal securities holdings and transactions, though specific requirements are set out in the firm’s code of ethics.
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Related Terms

Supervised Person

Who Is a “Supervised Person” at an RIA? The supervised person classification is broad by design

Code of Ethics

What Is a Code of Ethics for RIAs? The SEC’s Code of Ethics rule requires advisers

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