If an investment banking firm help a listed company to raise funds privately. Than the IB firm send the fund raising material to potential investors. Is it this matter consider material nonpublic? Or are there any violations invoved in here?
It’s probably material, nonpublic information.
There might be a violation if the person who disclosed the information were a covered person. There’s no violation on the bank’s part because the Code and Standards don’t apply to firms, only to individuals.