maratikus

I think once you get to Standard III, things will become clearer. If your business clarifies (for all clients) that paid customers receive privileged information, then you’re OK. I think you’d also have to clearly delineate what “privileged information” means. However, if your business doesn’t make such a distinction, then you’d have to mass broadcast the information equally.
In the Madison example, it is clear that the firm’s recommendation is not part of a tiered service. So trading on that information before the info becomes public (via the weekly publication) is a violation.
Not sure if this helps…