Yes.
Simply put I conceivably have access to a lot of non-pulic information. The vast majority of it I have never actually seen and have no reason to go looking for because it doesn't relate to anything I'm actually doing, but I have access to it and knowledge could be imputed to me.
Let's take an example. Company XYZ is considering purchasing a smaller company that will dramatically increase their profitability over the next 5 years. Company XYZ is a client of the firm and the negotiations, due diligence, and legal work are being handled by the transactional attorneys, who are physically located in an entirely different building than my office. During the negotiations, I puchase stock of Company XYZ without even knowing they're a firm client (we have literally hundreds of clients that I don't know about) and I make a big gain when the deal is announced. The SEC would look at the firm I work for, determine (correctly) that if I had done some poking around in the firm's computer file system I could have learned of the deal, and could decide to go after me for trading on material non-public information.
Lawyers get taken down on this pretty regularly, especially lawyers that operate in the securities field and thus "should know better."
I can get stung even if I don't actually have insider information and don't even know a stock I buy is through a firm client.
I got in hot water at work one time because I told my dad to buy stock in a particular company that was a firm client before I even worked at the firm. He sent an e-mail to my work account thanking me for a stock recommendation a couple years later (he made a lot of money) and that hit the firm's automatic sensor for potential insider trading.
In order to get around this I literally have to invest completely blindly, handing someone else my money and having them handle all the transactions while I give no input as to what companies I want to be part of the portfolio. It's a big disadvantage.
I have a lot of ideas; can't act on any of them or tell anybody else about them.
I am accepting new clients. If you are interested.
Troutbum