Employee personal trading

Reading 4.

7.0 Personal Investments and Trading

Prohibit covered employees and immediate family members from trading contrary to the firm’s recommendations , except under case of extreme financial hardship

If research team recommend both “buy” rating for A and B company.

Covered employee already has A shares, can emloyee

  1. Sell existing A company shares

  2. Sell existing A company shares and buy B company shares (switching)

Which one is allowed? 1) or 2)

Thanks!

After checking the curriculum, 1, simply sell the existing A shares is not allowed (except under case of extreme financial hardship)

But how about 2, just do the switching.

or

If research team have “buy” rating for A and new issue “strong buy” for B company.

Covered employee already has A shares. Can he switches A shares to B?

Can it count not trading in contrary ?