A. MATERIAL NON PUBLIC INFORMATION
#analyst-notes #code-of-ethics-and-standards-of-professional-conduct #integrity-of-capital-markets
Additional Compliance procedures, used typically in conjunction with an information barrier, include:
- Restricting or prohibiting personal and proprietary employee trading.
- Monitoring of firm and personal employee trading. Can be easily detected if employees and if firm requires to make periodic reports of their transactions on their own behalf or of their families.
- Placing securities on a restricted list if firm has material nonpublic information (unless this tend to reveal that the firm is engaged in a nonpublic engagement to the security).
- Using a stock watch list known only to a limited number of people when the firm has or may have material nonpublic information, to monitor transactions in specified securities.
- Limiting the material nonpublic information to persons who have a need to know it.
- ​Designating a supervisor who will have the authority and responsibility to decide whether information is public or lacking in materiality enough that it may be used for investment decisions.
- Firms should circulate written policies and guidelines employees and have seminars and courses about it
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