COE Comminication with clients

Guy’s i’m a little confused as to the procedure on the rule…if a analyst changes ones recommendation from a buy to a sell does one have to issue a report to your clients before informing them to about your decision?

I think that if you let all of your clients know simultaneously you’re fine. It’s when you inform one group of people before another that you get into violation territory. As a rule of thumb, however, always go from buy to hold to sell, never straight from buy to sell, or sell to buy. If there’s no hold in between, you just look dumb. Like Obama.

right i understand the (Fair Dealing), however i wanted to know whether a report has to be issued before a recommendation is given. (Ie if one is working on a tight time line and the recommendation has to be executed)?

I think as long as you make reasonable efforts to achieve public dissemination, it doesn’t matter whether it’s in report form or not. If there’s a time-crunch, you can always send an email notice to the entire client-base alerting them to the recommendation change before you publish the report.

yeah, makes sense…cheers