Series 7: 11.1.9 Publication Of Research Reports

11.1.9  Publication of Research Reports

FINRA requires member firms to establish and enforce written policies and procedures that manage conflicts of interest for analysts preparing research reports. These policies and procedures should focus on three critical areas:

• • The preparation and distribution of research reports
• • Public appearances by research analysts
• • The interaction of research analysts with individuals outside the research department

These policies must be designed to promote objective and reliable research that reflects the truly held opinions of the research analysts. Policies and procedures must prevent firms from using research reports to favor the interests of the firm or its customers. Conflicts of interest must be disclosed, whether they involve the member or the research analyst.

If a member firm participated in an IPO, it may not distribute a research report, and its research analysts may not m