Best personal trading compliance software
Five tools for the code-of-ethics work an adviser owes on its people's own trading: collecting holdings and transaction reports, clearing trades, pulling broker data and keeping the records Rule 204-2 asks for. Each cell says what the vendor's own pages state, and where they are silent. One is an employee compliance platform, two are compliance suites built for advisers, and two are modules of wider platforms.
Reviewed October 2026
Best overall
Comply
Its pages state holdings and transaction reports the system creates, pre-clearance, restricted lists and direct broker feeds, and its RIA product names Rule 204A-1.
Read the review of ComplyBest for a small RIA's 204A-1 reports
Smartria
Its trade page names initial, annual and quarterly reports under Rule 204A-1, and its home page records each employee's code-of-ethics attestation.
Read the review of SmartriaBest for access persons with accounts at many brokers
ACA Group ComplianceAlpha
Its page states integrated brokerage feeds, trade requests from a mobile app, restricted-security flags and email reminders, for firms of all sizes.
Read the review of ACA Group ComplianceAlpha
The comparison table
| Vendor | Access-person reports kept204-2(a)(13)(i) | Code acknowledgments kept204-2(a)(12)(iii) | Pre-clearance decisions and reasons kept204-2(a)(13)(iii) | Broker data feeds204A-1(b)(3)(iii) | Restricted listFirm's code | Reporting deadline reminders204A-1(b)(1)-(2) |
|---|---|---|---|---|---|---|
ComplyCompliance suite | Meets Holdings and transaction reports | Partial Policy certifications only | Partial Logged; reasons not stated | Meets Direct broker feeds | Meets Custom list, history archived | Partial Calendar; report dates unnamed |
SmartriaRIA compliance software | Meets Initial, annual, quarterly | Meets Code attestations recorded | Partial Audit trail; reasons not stated | Partial Custodians, none named | Meets Plus blackout periods | Partial General deadline reminders |
ACA Group ComplianceAlphaEmployee compliance platform | Partial Trade and holding data ingested | Partial Attestations; code not named | Partial Logged; reasons not stated | Meets Integrated brokerage feeds | Meets Restricted trades flagged | Partial Email reminders |
HadriusSupervision platform | Not stated Reports not named | Meets Code of Ethics attestations | Not stated | Not stated | Meets Plus blackout windows | Not stated |
Orion CompliancePlatform compliance module | Check with vendor Feature named, not described | Partial Code records; certifications | Not stated | Check with vendor Custodian feeds; staff not named | Not stated | Partial Calendar and alerts |
What access persons file, and when
Personal trading software exists because of one adviser rule. Rule 204A-1 makes every SEC-registered adviser adopt a code of ethics, and the code has to require access persons to report “personal securities transactions and holdings periodically”, with the firm reviewing what they file. An access person is a supervised person with access to nonpublic information about clients' trades or holdings, or one who is involved in making securities recommendations. Where advice is the firm's primary business, “all of your directors, officers and partners are presumed to be access persons.” For the code itself, read our guide to the investment adviser code of ethics.
Four filings the rule asks of an access person
| Filing | When | What it covers |
|---|---|---|
| Initial holdings report204A-1(b)(1)(ii)(A) | No later than 10 days after the person becomes an access person | Holdings no more than 45 days old |
| Annual holdings report204A-1(b)(1)(ii)(B) | At least once each 12-month period, on a date the firm selects | Holdings no more than 45 days old |
| Quarterly transaction report204A-1(b)(2)(ii) | No later than 30 days after the end of each calendar quarter | All transactions in the quarter |
| Pre-approval204A-1(c) | Before buying into an IPO or a limited offering | The firm's approval |
17 CFR 275.204A-1(b)-(c)
By our reading of that sentence, a calendar-quarter report falls due on these four dates each year. The annual holdings report has no fixed date: the firm picks one and keeps to it. Our code of ethics reporting calendar lays out the dates for each access person, including the 10-day window for a new hire.
Quarterly transaction reports, by our reading
| Quarter | Report due by |
|---|---|
| January to March | April 30 |
| April to June | July 30 |
| July to September | October 30 |
| October to December | January 30 |
17 CFR 275.204A-1(b)(2)(ii)
Not every security is reportable. Direct obligations of the US government, bank CDs, commercial paper, money market fund shares and open-end fund shares other than reportable funds are carved out of the definition. And a firm with one access person need not report to itself: “If you have only one access person (i.e., yourself), you are not required to submit reports to yourself”, provided it keeps records of all its holdings and transactions. That one-person adviser may not need dedicated software. State-registered advisers answer to their state's rules, which we did not read.
The records the software has to keep
Filing the reports is the access person's job. Keeping them is the firm's, under the books and records rule, and that is where software earns its place. Three of the table's columns are record lines from Rule 204-2: the reports, the code acknowledgments and the pre-approval decisions. The last one is the easiest to miss. The rule asks for “A record of any decision, and the reasons supporting the decision, to approve the acquisition of securities by access persons”. A system that logs “approved” with a timestamp keeps the decision; it only keeps the reasons if someone types them, or if the rule that cleared the trade is stored with it.
Code-of-ethics records under Rule 204-2
| Record | What it holds | How long |
|---|---|---|
| Each access-person report204-2(a)(13)(i); 204-2(e)(1) | A record of each report made under 204A-1(b) | Five years from the end of the fiscal year of the last entry, the first two in an appropriate office |
| Who the access persons are204-2(a)(13)(ii) | Names of people who are, or within the past five years were, access persons | Own period: reaches back five years |
| Pre-approval decisions204-2(a)(13)(iii) | Each decision and the reasons supporting it | At least five years after the end of the fiscal year the approval is granted |
| Code acknowledgments204-2(a)(12)(iii) | Each written acknowledgment, for people who are or within five years were supervised persons | Own period: reaches back five years |
| The code itself204-2(a)(12)(i) | The code in effect, or in effect at any time within the past five years | Own period: reaches back five years |
| Violations204-2(a)(12)(ii); 204-2(e)(1) | Each violation of the code and any action taken | Five years from the end of the fiscal year of the last entry |
17 CFR 275.204-2(a)(12)-(13), (e)(1)
Three of those records are set apart from the general period, and their own wording reaches back five years: the code, the acknowledgments and the list of access persons. The general period runs “not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in an appropriate office of the investment adviser.” Our books and records retention calculator works out those dates, and the Rule 204-2 guide lists every other record an adviser keeps. When you leave a vendor, these files have to leave with you.
Broker feeds and duplicate statements
A broker feed is the vendor collecting each access person's confirmations and statements straight from the broker. The rule gives that a purpose: no transaction report is needed “if the report would duplicate information contained in broker trade confirmations or account statements that you hold in your records so long as you receive the confirmations or statements no later than 30 days after the end of the applicable calendar quarter.” A feed that lands on time can stand in for the quarterly form. A feed that misses a broker leaves that person filing by hand, which is why the broker list is the first thing to ask for in a demo.
Broker-dealers have their own version. FINRA Rule 3210 governs the accounts a member's people open elsewhere, and it is the rule to read before buying personal trading software for a broker-dealer.
FINRA Rule 3210 in four lines
- Prior written consent of the member before opening an account at another member or financial institutionFINRA Rule 3210(a)
- Written notice to the executing firm of the person's association with the member, before openingFINRA Rule 3210(b)
- Duplicate confirmations and statements, or their data, sent on the member's written requestFINRA Rule 3210(c)
- An account opened before joining: consent obtained and notice given within30 calendar daysFINRA Rule 3210.01
Paragraph (c) is what a feed automates for a broker-dealer. Some accounts sit outside the rule: Supplementary Material .03 names unit investment trusts, municipal fund securities, 529 plans, variable contracts and redeemable securities of registered investment companies, among others. FINRA's rule page shows an amendment effective June 17, 2026; the wording above is the current text as read on October 22, 2026. A firm that is both an adviser and a FINRA member reads both rules; ask your compliance counsel how they fit together. For the rest of a member's duties, see FINRA compliance for small broker-dealers.
Pre-clearance and restricted lists
The rule asks for less pre-clearance than most software sells. Access persons must “obtain your approval before they directly or indirectly acquire beneficial ownership in any security in an initial public offering or in a limited offering.” That is the pre-approval the rule itself names. Clearing every trade, holding periods, blackout windows and a restricted list are choices a firm writes into its own code, for example because it trades the same names for clients.
So read the pre-clearance and restricted-list columns against your code, not against the rule. A firm whose code clears only IPOs and limited offerings needs a request form and a stored decision with its reasons. A firm that clears every trade against a restricted list needs a rules engine, and that is where these platforms differ most. If the code also asks staff to clear trades against client orders, the trade side of that review is covered in our comparison of trade surveillance software.
Which setup fits your firm
Firm size changes the answer more than features do. A one-person adviser keeps its own statements on file. A five-person RIA needs reports collected on time and acknowledgments kept. A broker-dealer with staff at many brokers needs feeds first. Pick your firm below to see which columns to read first and what to ask each vendor.
Read the reports and code acknowledgments columns first, then reminders.
6 lines for this firm
- 01Can access persons file initial, annual and quarterly reports in the system, and are the reports kept as filed?204A-1(b); 204-2(a)(13)(i)
- 02Does it remind each person before the 10-day initial and 30-day quarterly deadlines, and on the annual date we pick?204A-1(b)(1)-(2)
- 03Is each person's acknowledgment of the code, and of every amendment, kept as its own record?204A-1(a)(5); 204-2(a)(12)(iii)
- 04When an IPO or limited offering is approved, does the record keep the reasons with the decision?204A-1(c); 204-2(a)(13)(iii)
- 05Which brokers send feeds, and do statements arrive within 30 days of quarter end so they can replace the quarterly report?204A-1(b)(3)(iii)
- 06If we leave, in what format do the reports, acknowledgments and approvals come out?204-2(a)(12)-(13)
Personal trading is often bought as part of a wider compliance suite. If you also need a policy library, an annual review workflow and a compliance calendar, compare the RIA compliance software suites; a broker-dealer should read the broker-dealer compliance software comparison. Firms that would rather hand code-of-ethics administration to someone else can look at RIA compliance consultants.
Each vendor, read against the rule
Comply
Compliance suite- What it is
- One vendor with two product lines: Comply for RIA (formerly RIA in a Box) and Comply Platform (formerly ComplySci). The RIA product's FAQ says “The system automatically creates holdings and transactions reports”, which access persons review and attest to before submission, and that it helps meet “the SEC’s Rule 204A-1 (Code of Ethics Rule) requirements”. It can “Automate preclearance workflows and flag restricted activity”. The platform adds “the industry’s largest network of direct broker feeds” (no count is given) and pre-clearance requests sent from Teams or Slack.
- Who it fits
- An RIA that wants the code of ethics, the reports and the broker data in one place. Comply for RIA is “Purpose-built for RIAs navigating SEC and state requirements”; the platform names RIAs, wealth managers and broker dealers. No firm size is stated on either page.
- What the rule requires, and whether it meets it
- Access-person reports keptMeetsHoldings and transaction reports
- Code acknowledgments keptPartialPolicy certifications only
- Pre-clearance decisions and reasons keptPartialLogged; reasons not stated
- Broker data feedsMeetsDirect broker feeds
- Restricted listMeetsCustom list, history archived
- Reporting deadline remindersPartialCalendar; report dates unnamed
- Not verified by us
- Whether each pre-clearance record keeps the reason for the approval, whether the code-of-ethics receipt is a separate acknowledgment record, and the list of brokers its direct feeds cover.
Smartria
RIA compliance software- What it is
- RIA compliance software whose trade-monitoring page is built around Rule 204A-1: “Submit and review initial, annual, and quarterly reports with ease”, “Ensure pre-clearance, audit trails, and policy adherence are built in”, and “Tracking Blackout Periods & Restricted Lists”. Its home page says it will “Automatically record employee attestations of your firm’s code of ethics”.
- Who it fits
- A small or growing RIA that wants the three 204A-1 reports collected on a schedule. The trade page names Small Firms, Growth RIAs and Enterprise; the home page says “Trusted by thousands of RIAs, CCOs, and compliance consultants”. Broker-dealers are not named.
- What the rule requires, and whether it meets it
- Access-person reports keptMeetsInitial, annual, quarterly
- Code acknowledgments keptMeetsCode attestations recorded
- Pre-clearance decisions and reasons keptPartialAudit trail; reasons not stated
- Broker data feedsPartialCustodians, none named
- Restricted listMeetsPlus blackout periods
- Reporting deadline remindersPartialGeneral deadline reminders
- Not verified by us
- Which custodians and aggregators it integrates with (none are named), whether a pre-clearance approval stores its reason, and how report due dates are set for a firm whose code sets its own annual date.
ACA Group ComplianceAlpha
Employee compliance platform- What it is
- The employee compliance technology of ACA Group, a consulting and software firm, run on its ComplianceAlpha platform. The page says it will “Streamline employee trade pre-clearance and post-trade monitoring”, that employees submit trade requests in ComplianceAlpha or a mobile app, and that it can “Automate the management of certifications and attestations across your firm”. Broker statements are read into the platform as transaction and holding data.
- Who it fits
- A firm whose access persons hold accounts at many brokers, or one that wants consulting beside the software. The page says the solution offers “scalable oversight for firms of all sizes”, with customizable email reminders and “detailed logs of all compliance-related actions”.
- What the rule requires, and whether it meets it
- Access-person reports keptPartialTrade and holding data ingested
- Code acknowledgments keptPartialAttestations; code not named
- Pre-clearance decisions and reasons keptPartialLogged; reasons not stated
- Broker data feedsMeetsIntegrated brokerage feeds
- Restricted listMeetsRestricted trades flagged
- Reporting deadline remindersPartialEmail reminders
- Not verified by us
- The list of brokerage feeds that apply to your staff's accounts, whether the holdings and transaction reports themselves are kept as submitted, and whether a pre-clearance record keeps its reason.
Hadrius
Supervision platform- What it is
- A supervision platform for SEC- and FINRA-regulated firms. Its People Oversight module promises “real-time monitoring of personal trading, attestations, and certifications”; the home page says firms can “Monitor employee/firm trading in real time against restricted lists and blackout windows” and “automate Code of Ethics attestations”. The module page names “Immutable audit trails and one-click exam exports”.
- Who it fits
- A firm already using Hadrius for supervision or marketing review that wants staff trading in the same system. Its pages read for this table do not mention holdings reports, transaction reports, pre-clearance or broker feeds.
- What the rule requires, and whether it meets it
- Access-person reports keptNot statedReports not named
- Code acknowledgments keptMeetsCode of Ethics attestations
- Pre-clearance decisions and reasons keptNot stated
- Broker data feedsNot stated
- Restricted listMeetsPlus blackout windows
- Reporting deadline remindersNot stated
- Not verified by us
- How access persons file initial, annual and quarterly reports, whether it takes pre-clearance requests, and which brokers' data it receives for employee accounts.
Orion Compliance
Platform compliance module- What it is
- The compliance module of the Orion advisory platform. Its page offers to “Monitor and capture employee activities” and to “create and store records to enhance Code of Ethics compliance”. Its plans page lists Personal Trading, Certifications and Calendar as feature names, with no description, and says “Brokerage feeds are also automatically pulled in” without saying whose accounts.
- Who it fits
- A firm already on Orion that would rather add a module than a new vendor. Orion calls it “the regulatory technology platform for RIAs, broker-dealers, and compliance consultants”.
- What the rule requires, and whether it meets it
- Access-person reports keptCheck with vendorFeature named, not described
- Code acknowledgments keptPartialCode records; certifications
- Pre-clearance decisions and reasons keptNot stated
- Broker data feedsCheck with vendorCustodian feeds; staff not named
- Restricted listNot stated
- Reporting deadline remindersPartialCalendar and alerts
- Not verified by us
- A description of the Personal Trading feature: which reports it collects, whether it takes pre-clearance requests and keeps restricted lists, and whether its brokerage feeds cover employee accounts.
How we read these vendors
Questions firms ask
Does the SEC require personal trading software?
No rule names a tool. Rule 204A-1 requires a code of ethics under which access persons report their “personal securities transactions and holdings periodically” and the firm reviews them. The rule describes the reports and the review, not how they are collected. A firm with one access person need not report to itself at all, so long as it keeps records of all its holdings and transactions.
17 CFR 275.204A-1(a)(3), (d)
Can broker statements replace the quarterly transaction report?
Yes, when they duplicate what the report would say and arrive in time. The rule excuses a transaction report “if the report would duplicate information contained in broker trade confirmations or account statements that you hold in your records so long as you receive the confirmations or statements no later than 30 days after the end of the applicable calendar quarter.” That exception names transaction reports only, not holdings reports.
17 CFR 275.204A-1(b)(3)(iii)
Who counts as an access person?
A supervised person who has access to nonpublic information about clients' purchases or sales of securities or about a reportable fund's holdings, or who is involved in making securities recommendations to clients or has access to recommendations that are nonpublic. If advice is the firm's primary business, “all of your directors, officers and partners are presumed to be access persons.”
17 CFR 275.204A-1(e)(1)
Does every personal trade need pre-clearance?
The rule names two kinds only: access persons must get the firm's approval before acquiring “any security in an initial public offering or in a limited offering.” Clearing every trade is a policy a firm may write into its own code. Each approval under that requirement is kept with “the reasons supporting the decision” for at least five years after the end of the fiscal year in which it was granted.
17 CFR 275.204A-1(c); 275.204-2(a)(13)(iii)
What does a broker-dealer need for its people's outside accounts?
Under FINRA Rule 3210, a person associated with a member needs the member's prior written consent to open an account at another member or financial institution in which securities transactions can be effected and in which the person has a beneficial interest, and must tell the executing firm in writing of the association. On the member's written request, the executing member sends duplicate confirmations and statements, or the data in them. An account opened before joining needs consent and notice within 30 calendar days.
FINRA Rule 3210(a)-(c), 3210.01