Public Appearance

When making a public appearance as an analyst, do you have to disclose if family member’s own stock? Thanks

If they are the fee-paying client of the firm then probably not. If the analyst has a material interest in those holdings then yes. Anish

covered employees- or employees who have access to rating changes and time sensitive material (and such) – have to disclose all conflicts of interest. The stipulation is that holdigns of family members of covered employees also have to be fairly disclosed. So the answer is yes, you have to disclose at a public appearance.