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Standard Ⅱ: Integrity of Capital Markets
A. Material Nonpublic Information
Members in possession of nonpublic information that could affect an investment's value must not act or cause someone else to act on the information
Guidance
1)"Material"一if disclosure of information would affect a security's price or if an investor would want to know before making an investment decision
2)If price effect is ambiguous, information may not be considered material
3)Extends to info such as upcoming rating change, influential analysis to be released
4)Information is nonpublic until it has been made available to the marketplace. 比如 CFO告诉你的信息就属于material nonpublic.
5)Information made available to analysts in the conference call is considered nonpublic until it is made available to investors in general
6)"Act" includes related swaps and options, mutual funds with the security
7)If you possess material non-public information, act as you would if you did not know 提干中的“rumor”即可能设计到mosaic theory
8)Mosaic Theory—no violation when an analyst combines non-material non-public information with public information to reach conclusion
Recommended Procedures
1) Information barrier or "firewall" is recommended to control interdepartmental communications
2) Information barrier includes use of restricted list
3) Review employee trades
4) Increase review/restrict proprietary trading while firm is in possession of material nonpublic information
B. Market Manipulation
Do not engage in practices that distort prices or artificially inflate trading volume with intent to mislead market participants
Guidance
1)Do not engage in transaction-based manipulation-give false impression of activity/price movement; gain dominant position in an asset to manipulate price of the asset or a related derivative
2)Do not distribute false, misleading information
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发表于 2015-12-17 15:39:07
发表于 2016-1-9 07:19:58