Series 99: 3.2.3 FINRA Chinese Wall Rules

3.2.3  FINRA Chinese Wall Rules

Soon after passage of the ITSFEA, FINRA developed Chinese Wall rules to implement the ITSFEA’s requirement for information barriers. A Chinese Wall is an information barrier meant to prevent broker-dealer personnel from benefiting from leaks of corporate inside information. FINRA imposed the following Chinese Wall compliance guidelines:

• • Firms that conduct investment banking, research, or arbitrage activities must maintain restricted lists of securities in which proprietary and employee transactions are restricted or prohibited. A firm must review and investigate proprietary and employee trading for possible employee misuse of inside information in these listed securities. A firm also must keep watch lists where trading is not prohibited by employees, but they must be scrutinized carefully. Documentation of the dates and reasons why securities were added or deleted from these lists must be kept.
• • Firms must formalize