3621. Relationship with investment banking

A Dealer Member’s policies and procedures must specifically address preventing recommendations in research reports from being influenced by the investment banking department or the issuer.

The policies and procedures must specifically address, at a minimum:

1. prohibiting the approval of research reports by the investment banking department,

2. limiting the investment banking department’s involvement in the production of research reports solely to the correction of factual errors,

3. prohibiting and preventing the investment banking department from receiving advance notice of new ratings or rating changes on covered issuers, and

4. establishing systems to control and record the flow of information between analysts and investment banking department staff, regarding issuers that are the subject of current or prospective research reports.