10.7. Non-Interference with the Content of Research Reports

Legal and compliance staff checking for legal and compliance issues are the only non-research personnel who may review and approve/block a research report before it is published. Non-research personnel other than investment bankers may be allowed to read (but not approve/block) a pre-publication draft of a research report “for factual review.” The draft may even be reviewed by the subject company. But any review by non-research personnel or the subject company must follow these rules