The House of Representatives recently passed the Insider Trading Prohibition Act, which would bar “insider trading” – that is, securities trading, as well as related communications to others, by a person aware of material, nonpublic information (MNPI). The Act further provides, for purposes of establishing a violation of this prohibition, that it is not necessary for such a person to know specifically how the MNPI was obtained or whether a personal benefit was paid or promised. If passed by the Senate, the prosecution of insider trading would no longer be based solely on case law but would have statutory authority for the first time. One practice that could lead to the risk of insider trading is fund managers’ meeting with officers and executives of publicly traded companies – frequently referred to as “corporate access” – an integral aspect of the research processes of many equity-focused fund managers.  This three-part series provides an in-depth look at corporate access and the insider trading risks it can pose. The first article provides an overview of the context in which meetings between fund managers and issuers arise; the goals of corporate access; ways brokers are compensated for facilitating those meetings; and two key legal risks presented by this practice. The second article discusses how advisers can design policies to minimize the risks associated with these meetings, as well as six front-end controls that advisers should consider adopting. The third article analyzes several testing mechanisms that managers can use to ensure compliance with their policies governing corporate access, along with the SEC’s expectations regarding an adviser’s oversight, controls and procedures related to communications with issuer management. See our two-part series on mitigating insider trading risks: “Relevant Laws and Regulations; Internal Controls; Restricted Lists; Confidentiality Agreements; Personal Trading; Testing; and Training” (Sep. 27, 2018); and “Expert Networks, Political Intelligence, Meetings With Management, Data Rooms, Information Barriers and Office Sharing” (Oct. 11, 2018).