As defined en rule $204$A$-1$ The code of ethics rule if providing investment advice is the firms primary business who is affected a only those directors officers and partners who have access to certain non$-$public information or presumed to be access person be all of its directors officers and partners are presumed to be person see all of its supervised persons are presumed to be access persons only those directors officers and partners who are active in the business are presumed to be access person