Not needed if it is not a conflict of interest or a fee. Am i correct?
Correct. If Jenny works at a bar after hours - no conflict, so no disclosure. If Jenny provides investment advice at a bar and gets free drinks in the process - conflict. Must disclose.
Pimp, what about when you have material non public info and you did a complete due dillegence on the security and released the buy reco. Are you in volation or not? What does QBank say?
I would say yes you;d be in violation… It isn’t just if it’s a conflict but what one could perceive to be a conflict of interest…and that’s the case for the buy reco…
if you did your due dilly and arrived at a material non public conclusion on your own (without confirmation that it is non public, just your hunch) then you are fine. BUT if you did all that and then overheard the CEO talking, you can’t release your report, must try to get them to release the informaiton and can’t cause anybody to trade on what you know until after the info becomes publicly available.
strikershank Wrote: ------------------------------------------------------- > if you did your due dilly and arrived at a > material non public conclusion on your own > (without confirmation that it is non public, just > your hunch) then you are fine. yep, mosaic theory.
if it’s non-material non-public and you issue a buy rec based on the mosaic theory, there is no violation as long as your recommendation has a reasonable basis and other stuff.
Agreed. But if you are in possession of material non-pubic information, then it is obviously a violation. asdffdsa Wrote: ------------------------------------------------------- > strikershank Wrote: > -------------------------------------------------- > ----- > > if you did your due dilly and arrived at a > > material non public conclusion on your own > > (without confirmation that it is non public, > just > > your hunch) then you are fine. > > yep, mosaic theory.
“If public dissemination is not possible, the member or candidate must communicate the information only to the designated supervisory and compliance personnel within the member or candidate’s firm and must not take investment action on the basis of the information.” So, as i thought you SHOULD NOT COMMUNICATE MNP to your MANAGER 
is’t supervisory = manager?
comp_sci_kid Wrote: ------------------------------------------------------- > “If public dissemination is not possible, the > member or candidate must communicate the > information only to the designated > supervisory and compliance personnel within the > member or candidate’s firm > and must not take investment action on the basis > of the information.” > > So, as i thought you SHOULD NOT COMMUNICATE MNP to > your MANAGER it says only to DESIGNATED. I dont know but i wouldnt disclose it to my manager. Maybe i am wrong
this is right, because that person might use the info for themselves. you are supposed to keep as tight a lid as possible on this, but you are required to tell your compliance officer so that they may monitor accounts for funny trading activity in the security. i work in a sell side firm and this is the standard practice in my office and elsewhere to my knowledge. comp_sci_kid Wrote: ------------------------------------------------------- > comp_sci_kid Wrote: > -------------------------------------------------- > ----- > > “If public dissemination is not possible, the > > member or candidate must communicate the > > information only to the designated > > supervisory and compliance personnel within the > > member or candidate’s firm > > and must not take investment action on the > basis > > of the information.” > > > > So, as i thought you SHOULD NOT COMMUNICATE MNP > to > > your MANAGER > > it says only to DESIGNATED. I dont know but i > wouldnt disclose it to my manager. Maybe i am > wrong