9.3.7. Separation of Research and Investment Banking
FINRA requires a firewall between a member firm’s research and investment banking departments, meaning that the firm’s research and investment banking departments must be separated both physically and in terms of how their information is stored electronically. In other words, an investment banker should not be able to access the computer system on which research analysts store their data, nor should the banker be able to physically enter the part of a building where the analysts’ offices are located. In addition, communication between the investment banking and research departments is subject to supervision by the legal and compliance departments, a practice known as chaperoning.
Marketing materials distributed to clients or potential clients may not mention the i
