This relates to II(A) Material Nonpublic Information stating: “If a member or candidate determines that information is material, the member or candidate should make reasonable efforts to achieve public dissemination of the information. This effort usually entails encouraging the issuer company to make the information public. 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’s or candidate’s firm and must not take investment actions on the basis of information.” Now it says clearly that you must encourage the issuing firm to disseminate the info, but if they don’t are you somehow allowed to disseminate it or are you prohibited to do so? It is a bit confusing because it says ‘if public dissemination is not possible’ but it doesn’t state clearly any other possible ways.
I don’t want to say 100%, but I’m fairly sure you can’t just go ahead and disseminate it yourself. Your job is to make sure that neither you nor anyone else can act on that material nonpublic information. Now I once saw a Qbank question when someone at your firm is going to execute a trade when you find out material nonpublic info that would turn said trade into a bad idea. You encourage the firm in question to make the info public, and they don’t. The question stated that you obviously cannot tell your firm about the info, nor can you request to put this stock on a restricted list, since that would indirectly cause the trader to act on this information. Perhaps in some cases it just comes down to making sure no one else knows about the nonpublic info?
Basically, if they don’t disseminate the information you cannot. You cannot trade on it, you cannot act on it, you cannot mention it. You basically forget about it. There is a couple qbank questions that confirm this but I am way to tired to dig through it to find them.