The institute has urged fund companies to adopt stiff restrictions on personal trading by fund managers.

Specifically, the memo said, four of the investigations involve personal trading in securities of companies covered by the analysts.

On Jan. 14, he said, the commission will consider a proposal to require portfolio managers to report their personal trading in funds they manage.

Brokerages are also more used to dealing with restrictions on the personal trading of their research, trading and other employees.

"The more time we spent on the site, we realized it was a whole new dimension in personal trading."

Michael Dever began personal discretionary trading in 1979.

Most fund companies allow, and some encourage, personal trading by portfolio managers and other fund employees.

In an interview, he said the industry "is not rife with enforcement problems" involving personal trading.

The most logical response might be to ban personal trading altogether.

And personal trading should be consistent with investment recommendations, the rules say.