If an independent analyst receives flat fees for the research from the issuer company, but he doesn’t disclose it to his clients. Is it violation or not?
I think it is violation.
Yes of course
It’s not about the kind of compensation, it’s about receiving compensation from an issuer company the analyst is covering and potentially recommending to clients. Thus, any form of compensation need be disclosed. Investor’s themselves can then assess whether they think the analyst is really independent ;-).