191. In addition to the adviser, the following persons are deemed to have knowledge of the investment program of an adviser who manages a portfolio, if they participate in formulating his investment decisions or his recommendations to the client for whom he manages the portfolio, or learn of them before they are implemented:(1) every partner of the adviser;
(2) every legal person that is an affiliate of the adviser;
(3) every officer or director of the adviser or of a legal person that is an affiliate of the adviser;
(4) every member of the personnel of the adviser or of a legal person that is an affiliate of the adviser.