bmaggie

An unpaid intern at an investment firm has the task of photocopying unannounced investment recommendations after all regular employees have left for the day. With respect to Standard VI(B), Priority of Transactions, the firm:

A) cannot be in violation because Standard VI(B) does not address this issue.

B) is acting appropriately by having an unpaid intern do the job.

C) is probably violating the Standard.

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Among other things, Standard VI(B) covers how the firm keeps unannounced information confidential. At a minimum, the intern should be supervised by someone familiar with the Code and Standards. The firm needs to have adequate procedures for preventing the dissemination of information before it is released to the public. One method of doing so is to limit the number of access persons privy to confidential information. An intern should not be an access person.

zaestau

c