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Nara is right It seems a lot more like PM than ethics.
I think the key word is NEEDS. It’s another one of those absolutes that give clues to a question. The need comes from discussing the aberration from the norm, the low beta for the return. You NEED to discuss that.
You can suck a little more juice out of this question, too. What if it said he communicates it to his largest clients only? That’s a violation. If he communicate to to all clients first he can then call the largest clients first and that isn’t a problem.
What if he used this info to purchase stocks in ALL discretionary portfolios?…another violation.
What if he only communicated it to clients whose suitability profile fit the stock. That is not a violation to communicate based on suitability. You do not have to communicate everything to everyone.

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