How often must an access person update their personal security holdings report after the initial submission?

An access person is typically required to update their personal security holdings report at least once every 12 months following the initial submission of that report. This requirement is designed to ensure that the organization has up-to-date information about the personal investments of individuals who may have access to material nonpublic information.

By updating the report annually, firms can effectively monitor any potential conflicts of interest and ensure compliance with regulatory standards. This periodic update helps manage the integrity of the investment process and maintain transparency among employees with privileged information. Therefore, the expectation is that access persons will formally document their holdings on an annual basis, ensuring that the organization is kept informed of any significant changes in their investment positions.