Ethics: Numbers to remember

It seems like Level I had way more numbers to remember for ethics, i.e. # of years for this or that. Anyone have a list of #'s for ethics, i.e.

  • Senior officer of the firm attests every 1 year to a firm’s clients that the firm adheres to the ROS policy
  • Record retention 7 years

Investment policy statements should be updated every 1 year

ROS:

Rating system should incorporate 3 elements: (1) Rating category (absolute vs relative), (2) Time horizon category, (3) Risk category

Reports/recommendation should be updated at least quarterly

ROS Recommendations

  • 30 days quiet IPO / 10 days quiet secondary
  • 30 days before and 5 days after restricted period for trades wrt research report
  • Hold positions for at least 60 days
  • 12 months before and 3 months after disclosure for firm compensation

^you beat me to it

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.

What if a company owe less than 1%, are we compel to disclose it? i have wanted to ask that question for some times now.

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.