Presumably, the analyst created the report with information
available to the public (mosaic theory) using his or her expertise to interpret the
information. The analyst’s hard work, paid for by the client, generated the
conclusions. Simply because the public in general would find the conclusions
material does not require that the analyst make his or her work public. Investors
who are not clients of the analyst can either do the work themselves or become a client of the analyst if they want access to the analyst’s expertise. |