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 f