Section 204A, added in 1988, requires every adviser subject to section 204 to put in place, keep up and enforce written procedures, shaped to its own business, that can reasonably be expected to stop the adviser or anyone associated with it misusing material non-public information, in breach of the Advisers Act, the Exchange Act or the rules. Restricted lists, information barriers around expert-network and private-side contacts, trade surveillance against news events and training are the usual shape.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.