Abstract

The National Association of Securities Dealers and the New York Stock Exchange recently have adopted and then amended new rules relating to research analyst conflicts of interest. However, open questions remain, and these two self‐regulatory organizations (SROs), in collaboration with the SEC, must provide further guidance on the application of these rules to various day‐to‐day situations such as an analyst receiving a customer inquiry concerning investment banking capabilities, a firm’s participation in an investment banking syndicate after the firm’s analyst has begun research coverage of the issuer, procedures for analysts to conduct due diligence, publishing research reports on an issuer while a firm is engaged in a distribution of the issuer’s securities, and analysts’ limitations during distribution quiet periods.

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