The short answer: At an investment adviser, a skills screen misses the part of a support role that carries regulatory weight: discretion. An assistant who sees nonpublic client trading information can count as an access person under SEC Rule 204A-1 and owes a holdings report within 10 days. Close the gap three ways: map the access, test judgment, confirm week one.
Written for the HR lead or chief of staff who hires support staff at a financial services firm of 50 to 500 people. The rules cited are for US investment advisers and UK investment firms; broker-dealers have their own, and the method works the same way at a family office.
There were 16,544 investment advisers in 2025, and 92.8% of them employed 100 or fewer people, per the Investment Adviser Association’s 2026 industry snapshot. On a team that size, the executive assistant often sees what the principal sees. That means the calendar, the meetings that moved, and sometimes what the firm is about to buy or sell. Securities rules notice that, even when a hiring checklist doesn’t. The seat comes with duties.
In the searches we run for financial firms of 50 to 500 people, hiring usually sits with one person who owns the whole process. What a support seat needs often sits beyond the job description, and access is the clearest case. A description built from software and tasks tends not to say what the hire will see. That part goes unscreened.
This guide covers why discretion carries more weight in a support hire and a three-part method to screen for it. It then sets out what common screening steps miss, when the access line moves, and three signals that the screen works. The method reflects North Bridge’s work placing HR, administrative and executive support talent in financial services.
Why does discretion matter more in a financial services support hire?
Discretion matters more because the rules attach to access, not to job titles. Under SEC Rule 204A-1, an adviser’s code of ethics covers any supervised person with access to nonpublic information about clients’ trades. That person reports holdings within 10 days and transactions every quarter. A typing test shows none of this.
The rule’s timetable is specific. The first holdings report is due within 10 days of becoming an access person, and its information must be current as of a date no more than 45 days before the person became one. Transaction reports follow no later than 30 days after each calendar quarter ends, and a fresh holdings report comes at least once every 12 months. Access persons also need the firm’s approval before buying into an initial public offering or a limited offering.
None of that is a skill. It’s a set of habits the hire either brings or doesn’t: asking before acting on what they’ve seen, keeping a principal’s week out of conversation, reporting a mistake promptly. The rule itself requires supervised persons to report code violations promptly to the chief compliance officer. A screen built from software and tenure can’t tell you which kind of person you’re about to give the calendar to.
Enforcement reaches people as well as firms. In fiscal 2025 the SEC filed 456 enforcement actions, 303 of them standalone, and about two-thirds of the standalone actions charged one or more individuals. Those figures cover every kind of case, not support staff. They show where the rules point.
How do you screen a support hire for discretion?
Screen for discretion by starting from the seat, not the candidate. Three foundations do the work: map what the role will see, test judgment with questions that have no answer to repeat, and confirm the week-one paperwork. The 10-day holdings report gives the method its deadline. Discretion gets tested before the offer.
1. Map what the seat can see before you write the posting
The detail most screens miss is that access, not title, decides which rules apply. In London, the FCA’s conduct rules list a personal assistant or secretary among ancillary staff, so the conduct rules may not reach the role. Yet a firm may still have to keep personal account dealing arrangements that cover staff with access to inside or confidential client information. Write down what the seat will see in week one, then screen against that list.
2. Ask for a sensitive story with the names taken out
North Bridge anonymizes by default, because an example stops being safe once it attaches to a real person. Ask candidates the same thing: describe a sensitive situation from a past role without naming anyone. The strong answer keeps the lesson and loses the identifiers. A candidate who names the firm, the principal or the deal has answered the question you were really asking. Structured reference checks can confirm the same habit from the other side.
3. Confirm the week-one paperwork before the start date
Rule 204A-1 requires each supervised person to receive the code of ethics and acknowledge it in writing. Get the acknowledgment signed before day one, and put the initial holdings report on the offer checklist with the compliance contact named. Its 10-day clock starts when the person becomes an access person, not when someone remembers to tell them.
List what your last assistant could see in week one: calendars, deal names, client trades. Each item should map to a step in your screen. If one doesn’t, that access was handed over untested. Not sure where the gaps are? Compare notes with us
What a software test, a typing test and a resume can’t show
The governing rule is that a screening step proves only what it measures. Software tests, typing tests and resumes measure tasks, and discretion is a judgment. SHRM found 80% of HR professionals have the greatest difficulty finding candidates with systems and resource management skills, a group that includes judgment.
The table below sorts the usual screening steps by what they can and can’t show about a support hire.
| Screening step | What it shows | What it can’t show |
| Software test | Speed in the tools | What the hire does with what’s on screen |
| Typing test | Accuracy under time | Whether they forward what they type |
| Resume and tenure | Years in a similar seat | How they handled access in that seat |
| Structured interview | Judgment, when the questions probe it | Nothing, if it only asks about tasks |
| Reference check | How the hire behaved over time | Little, unless you ask about confidentiality |
The structured interview is the strongest tool on the list. In a 2022 re-analysis summarized by SIOP, structured interviews had the highest mean operational validity, at .42, ahead of job knowledge tests at .40 and work samples at .33. That edge only reaches discretion if the questions do.
Hiring pressure makes the gap easy to miss. In SHRM’s 2026 Talent Trends survey of 2,094 HR professionals, 68% reported difficulty recruiting full-time employees, and 53% of those said it had become harder than a year earlier. Under that pressure, a screen tends to shrink to what it can check fast. Judgment often isn’t on that list.
The move many firms miss is to add one discretion question to every support-role interview and score it like any skill. Many firms treat discretion as a reference-check afterthought. A scored answer is a record you can compare across candidates. Our piece on why vetting outranks speed argues that speed-to-fill is the wrong measure of a hire.
If your support-role scorecard tests only skills, add one line: how the candidate handled something they couldn’t repeat. A good answer names no one. A scorecard without it hires for speed and hopes for discretion. Want a second read on yours? Let’s talk it through
Three moments the access line moves on a lean team
The access line moves when the seat changes, not when the calendar turns. Three moments justify a fresh look: a new principal, a London hire, and a deal or fund launch. On a lean team one assistant often covers several people, so a single change can widen what they see.
- A new principal. An assistant who moves from an operations lead to a portfolio manager may cross into access-person territory without changing title. Re-map the seat and confirm the code of ethics before the first week together.
- A hire in London. The FCA’s personal account dealing rules can reach support staff with access to confidential client information, depending on the firm’s business and the person’s role in it. Your compliance team will know which part applies. If the firm is an issuer or acts for one on a deal, UK MAR Article 18 adds an insider list, kept at least five years.
- A deal or a fund launch. A transaction puts names and numbers on calendars that were routine the week before. Treat it as a new seat for screening purposes.
Automate the timing, never the human moment. A calendar reminder to re-map access when a principal changes costs nothing. The conversation about what the assistant will now see stays between people.
Three signals your screen is testing discretion
Three signals show whether the screen sees discretion. Track an access map on every support requisition, a scored discretion question in every interview, and an initial holdings report filed within 10 days for every new access person. Aim for all three, because each fails in a different place.
Read them together. If the access map exists but reports run late, the handoff between hiring and compliance is the problem. If reports are on time but no interview question scores discretion, the firm is compliant on paper and untested in practice. If neither holds, access is being discovered after the start date.
Set the baseline before the next requisition opens by writing the access map for your current support seats. If the same gaps keep surfacing, our list of process warning signs is a useful next check.
Run the checklist test: open your last three offer checklists and look for the initial holdings report step. It should sit beside the start date. If it isn’t there, the 10-day clock started with no one watching it. Planning a search? Ask how we’d screen
Frequently asked questions
Discretion is the part of the job the screen has to see
A skills screen confirms the tasks and misses the judgment the rules depend on. With a 10-day holdings clock under Rule 204A-1, and 80% of HR professionals struggling most to find systems and resource management skills, which include judgment, the gap sits in the interview. Firms that close it map the seat, score discretion and finish the paperwork early.
The access map, the compliance calls and the code of ethics are yours. Finding support talent who handle what they see the way your principals expect is where North Bridge fits in, through direct-hire and contract searches across Chicago, New York, Miami and London. If your next support seat will see more than its title says, talk to North Bridge before the posting goes live.
References
- “2026 investment adviser industry snapshot shows continued growth in demand for adviser services.” Investment Adviser Association. Published June 3, 2026. Verified live October 21, 2026.
- “17 CFR 275.204A-1, Investment adviser codes of ethics.” US Securities and Exchange Commission, via the Electronic Code of Federal Regulations. Published undated (current as of October 16, 2026). Verified live October 21, 2026.
- “SEC Announces Enforcement Results for Fiscal Year 2025.” US Securities and Exchange Commission. Published April 7, 2026. Verified live October 21, 2026.
- “COCON 1.1 Application.” Financial Conduct Authority Handbook. Published September 1, 2026. Verified live October 21, 2026.
- “COBS 11.7 Personal account dealing.” Financial Conduct Authority Handbook. Published October 23, 2025. Verified live October 21, 2026.
- “Is cognitive ability the best predictor of job performance? New research says it’s time to think again.” SIOP, The Industrial-Organizational Psychologist (summarizing Sackett, Zhang, Berry and Lievens, Journal of Applied Psychology, 2022). Published undated. Verified live October 21, 2026.
- “SHRM Unveils 2026 Talent Trends Report: Data-Driven Insights for the Future of Work.” SHRM. Published April 27, 2026. Verified live October 21, 2026.
- “Market Abuse Regulation, Article 18: Insider lists.” legislation.gov.uk (UK MAR, as amended). Published undated (last amended June 29, 2021). Verified live October 21, 2026.
