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hard ethics questions list

Let's start a thread of counter-intuitive Ethics, ROS, Prudent Man, Soft Dollar items. I'll get it started:


? Analyst difference of opinion with investment committee – leave name on report and document difference of opinion
? Misconduct - Rasmussen has clearly come upon an error in policies … Should all internal communications within the firm not satisfy her concerns, Rasmussen should consider reporting the potential unethical activity to the appropriate regulator
? Market Manipulation – Achieve public dissemination - If a member or candidate determines that information is material, the member or candidate should make reasonable efforts to achieve public dissemination of the information. This effort usually entails encouraging the issuer company to make the information public. If public dissemination is not possible, the member or candidate must communicate the information only to the designated supervisory and compliance personnel within the member’s or candidate’s firm and must not take investment action or alter current investment recommendations on the basis of the information.
? Issue press release - If material nonpublic information is disclosed for the first time in an analyst meeting or call, the company should promptly issue a press release or otherwise make the information publicly available.
? Firewalls – Prevention of Personnel Overlap - an analyst who follows a particular company may provide limited assistance to the investment bankers under carefully controlled circumstances when the firm’s investment banking department is involved in a deal with the company. That analyst must then be treated as though he or she were an investment banker; the analyst must remain on the investment banking side of the wall until any infor- mation he or she learns is publicly disclosed
? Watch lists and restricted lists - The most prudent course for firms is to suspend arbitrage activity when a security is placed on the watch list

Soft Dollar
- consent for principal trades

ROS
- Immediate family defined as living in your home (as opposed to relatives in other domiciles)

Brokerage from an agency trade can be used to pay other clients research too. But manager should ensure this particular client also will benefit from other client's brokerages.

Vol 1, p. 192

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oh this is exactly what i needed. thank you!

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@ramdabom .. how did u get those .. ive solved so many examples i came across none of em !! ...

Anyways assuming all you have written is perfect correct .. Thank you .. Good Luck

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? Firewalls – Prevention of Personnel Overlap - an analyst who follows a particular company may provide limited assistance to the investment bankers under carefully controlled circumstances when the firm’s investment banking department is involved in a deal with the company. That analyst must then be treated as though he or she were an investment banker; the analyst must remain on the investment banking side of the wall until any infor- mation he or she learns is publicly disclosed

More on this...

You cover REITs and overhear in the elevator, accidentally, the iBankers talking about a major deal going down for the X REIT.

You go back to your desk, and run your daily screen, like you always do. X REIT pops up as the best security on the list. You conduct thorough research and conclude it is a great stock. You recommend its addition to the portfolio. NOTE: even if you didn't hear about the deal, you would have still reached the same conclusion and recommendation.

Violation because once you are aware of any Ibanking deals - you must act as if you are an Ibanker for that deal until it closes. So you can't act on it whatsoever, right? That would be a violation of Material NonPublic information...



Edited 1 time(s). Last edit at Thursday, June 2, 2011 at 12:41PM by tiredofstudying.

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Also, for Diligence and Reasonable Basis, let's say you use research from a fellow Economist WITHIN your company.

a. If you take a direct quote/piece of writing from him:

-Cite Economists name.
-Give any related risks/caveats related to the quote.
-Document/maintain a copy of the Economists report.

b. If you use his forecasts/strategy in your report. No quotes/direct pieces.

-Cite Economists name (Or is general strategy/forecasts of Economists considered Company property, and thus does not need to be cited?)
-Ensure the Economist's work has a diligent and reasonable basis before using it (I dont think this is necessary - if you must verify and document the research is valid --- what is the point of having an Economist?)
-Ensure you have a diligent and reasonable basis for including the Economist's research and your assessment of its impact on your industry (This makes more sense to me)
-Give any related risks/caveats related to the quote.
-Document/maintain a copy of the Economists report.

Any thots?

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- Immediate family defined as living in your home (as opposed to relatives in other domiciles)

After just reading through the ROS, i find this hard to believe. I feel like they could easily throw a question about us where your mum who doesn't live with you trades on information given from you. I assume this would be a violation of the standards regardless though.

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