Overview of Covered Accounts & Private Investments

As a regulated business, employees are required to disclose certain personal investment activity for themselves and certain family members. Below is a summary of the requirements.

• Family Members subject to the policy requirements include spouse/domestic partner, dependent children, and any other relative that lives in the employee’s household.
• Covered Accounts that require disclosure are accounts that you or your Household Family Members control or in which you have a direct or indirect beneficial ownership, including:
  • Trading Accounts: Accounts that can trade securities (stock, bonds), futures, REITs, FX or derivatives.
  • Self-Directed Retirement Accounts: Accounts where you or a Household Family Member direct trading (e.g., IRAs, SIPPs, ISAs). This does not include 401K accounts, pensions or other accounts that can only trade mutual funds.
  • Employee Stock Accounts: Stock plans provided by current or former employers.
  • Custodial Accounts: Stock certificates held by a custodian without trading ability.
  • Professionally Managed Accounts: Accounts managed by an investment manager who has exclusive discretionary authority over investment decisions in the account.
• Private Investments that require disclosure include private placements (e.g., hedge fund, private equity fund, venture capital fund) or investments acquired in a private securities transaction. For each, you will need to disclose the name of the fund or private investment, and the amount invested.
• All Trading Accounts and Self-Directed Retirement Accounts must be held at a Designated Broker (see attached list for approved Designated Brokers by country). All accounts at non-Designated Brokers must be closed. You are expected to complete any account cleanup and if possible, close accounts at non-Designated Brokers prior to your start date. Accounts closed prior to hire date do not require disclosure.
• For each Covered Account, you will need to provide the following information:
  • Account Name and Account Number
  • For accounts other than Professionally Managed Accounts, a recent account statement or holdings report
  • For Professionally Managed Accounts, an advisory agreement or documentation showing discretionary authority. The Employee Compliance Team can provide a managed account letter for your adviser to sign in lieu of the advisory agreement.

As of your start date, you and your Household Family Members are not permitted to trade in any Covered Accounts until they are disclosed, and you receive approval. Trading will not be permitted in accounts at non-Designated Brokers once you join. In addition you and your Family Members will be subject to Citadel policies regarding specific trading and investments activity.

Contact EmployeeCompliance@Citadel.com with any questions.

Approved Designated Brokers

Note: U.S. listed futures may only be held and traded in an account at Interactive Brokers.

If you have questions on accounts in other countries, please contact EmployeeCompliance@citadel.com to see if there is additional broker coverage.

Last Updated October 23, 2024