When can an access person be required to provide an updated report of their securities?

An access person is typically required to provide an updated report of their securities at least once every 12 months. This reporting requirement is part of the compliance framework designed to monitor potential conflicts of interest and ensure that access persons act in accordance with their firm's policies and ethical standards regarding trading and reporting of personal securities transactions.

Requiring a report on an annual basis allows firms to keep track of changes in the holdings of access persons without overwhelming them with the need to report after every transaction or market change. This timeframe balances the need for oversight with practicality, ensuring that the information is both relevant and manageable for compliance officers to review.

Other options reflect scenarios that may not align with the established reporting requirements. For example, expecting reports only after significant market changes or after each new investment would not provide a consistent framework for monitoring and could result in gaps in compliance. Similarly, requiring updates at the start of each fiscal quarter might introduce unnecessary complexity, as the annual reporting suffices to capture a comprehensive view of the individual's securities holdings over time.