Firewall Between a Member Firm and a Subject Company
A member firm may not submit any portion of a research report to the subject company prior to publication, except as necessary to verify the factual accuracy of its information. If sections of a report must be submitted, the firm must comply with these additional demands: (1) the sections in question must not contain the research summary; (2) the complete draft of the report must be reviewed by legal or compliance personnel prior to delivery; (3) if, subsequent to the