Who Is a “Supervised Person” at an RIA?
The supervised person classification is broad by design — it captures essentially anyone acting under the firm’s direction in connection with investment advisory activities, not just those with client-facing titles. These individuals are subject to the firm’s code of ethics, recordkeeping obligations tied to their conduct, and in many cases, personal trading and reporting requirements.
Firms need to maintain an accurate list of supervised persons and ensure each one has received and acknowledged the firm’s compliance policies — a common exam finding is an incomplete or outdated supervised persons list.