Insider trading remains a perennial focus for the SEC. The SEC Division of Examinations recently issued a risk alert (Risk Alert) flagging numerous deficiencies it has observed regarding investment advisers’ policies, procedures and practices for handling material nonpublic information (MNPI). The Risk Alert focuses on compliance with Section 204A of the Investment Advisers Act of 1940 and Rule 204A‑1 thereunder, which govern, respectively, policies and procedures for handling MNPI and reporting of personal securities transactions and holdings. This article discusses the key takeaways from the Risk Alert, with commentary from Ranah Esmaili, partner at Sidley Austin, and Philip Moustakis, counsel at Seward & Kissel. See our two-part series on current insider trading regulatory and enforcement environments: “SEC Information Gathering and Enforcement” (Jul. 8, 2021); and “Appropriate Policies and Procedures” (Jul. 15, 2021).