614****46392024-04-27 12:40:14

Mattock, head of research dept. of H&V, a brokerage firm, has decided to change recommendation for Timber from buy to sell. In line with H&V’s procedures, she orally advises other executives of recommendation change before publication. After her conversation with Frampton, one of the executives of H&V, Frampton immediately sells (front running) Timber stock from his own account and some discretionary client accounts. Other personnel also inform certain institutional customers of the changed recommendation before publication and dissemination to all H&V customers. Comment: Mattock violated Standard IV (C) by failing to supervise reasonably and adequately the actions of those accountable to her. She also must ensure that her firm has adequate procedures for unethical practice. Meanwhile, violate II(A), VI(B) Priority of Transaction. 请问为什么 违反了II(A) 投资公司的recommendation 难道算是MNI 吗？这里公司将消息提前传达给了一些客户，但为什么又没有违反III(B) ?