1)“Prohibit covered employees and members of their immediate families from trading in a manner that is contrary to, or inconsistent with, the employees’ or the firm’s most recent, published recommendations or ratings, except in circumstances of extreme financial hardship.” Does this mean that if Joe Shmo’s Bank is issued a negative rating by the employee’s company, the employee and their family members can’t trade AT ALL in Joe Shmo’s Bank, even through a different broker? So John Smith AND his wife can’t trade in that stock even through a different brokerage (e.g., Etrade)? 2)Prohibit covered employees and members of their immediate families from purchasing or receiving securities prior to an IPO for subject companies AND OTHER COMPANIES IN THE INDUSTRY or industries assigned. So if I’m gung ho on buying Bank of America before an IPO, I can’t, but I also can’t buy Chase stock either?
- The only thing you could do then is sell the stock that you own in joe shmo’s bank, because it is consistent w/ the rating. Making sure, of course, that the information has had plenty of time to disseminate. 2) I think that this is because an IPO will affect many of the companies in that same industry.