Procedures for compliance

If members receive inside information, they shall make efforts to achieve public dissemination of material nonpublic information disclosed in breach of duty. Including encouraging the company to make the information public.

Firms should adopt written compliance procedures. The most common approach is an information barrier known as a "fire wall", Which prevents communication of material nonpublic information and other sensitive information between departments.

The minimum elements of such a precaution include the following:

• Control (preferably by compliance) of interdepartmental communications.
• Review of employee trading with a combination of "watch," "restricted," and "rumor" lists.
• Procedures to limit flow of information between departments and of the enforcement of them.
• Careful review or restriction of proprietary trading while the firm is in possession of material nonpublic information.