Quiet periods of 30 calendar days from issuance for IPOs and at least 10 calendar days from issuance for secondary offerings are recommended.
Firms should ensure that all conflicts of interest are disclosed in research reports. It is recommended
whether the firm or any of its affiliates holds one percent (1%) or more of any class of the outstanding common equity of the subject company as of five (5) business daysprior to the issuance of the research report;
whether the author(s) of the report received a material gift from the subject company in the previous 12 months.
Under the ROS, it’s recommended that firms disclose whether themselves, or any affiliates, own 1% or more of any class of outstanding shares within the last 5 business days. That one always gets me, where its business versus calendar for others.