Compliance checklist regarding research rules 15-a6 reg. AC

1. Research and Analyst Compliance Checklist
Person performing review and date: ______________________________________________________/
date: ______________________________________________________
________________________________________________/
Date of
Date/Time
Date/Time
Compliance
Processing
Operational
Operational
required
Input date next to applicable or required items:
place:
took place:
Review:
Review:
Disclosures-
Required Disclosures
• If the firm was a co-manager of a public offering (equity or debt) by the
subject company,
• Whether the firm received compensation from the subject company for any
reason (e.g. investment banking or non investment banking purposes), and
• Whether the firm has any relationship with the subject company.
If the report or similar communication recommends the purchase or sale of a
f
specific security, the report must indicate the following:
following
• If the firm makes a market in the security with customers on a principal basis.
• If any employees of the firm preparing the report have positions or own options
in the security.
• If any employees are a director of the issuer
• Also any potential conflicts of interest that might inhibit the analyst from
rendering unbiased and objective advice should be disclosed. Employees
cannot take positions or liquidate holdings before public customers have an
opportunity to do so.
Required Certifications-The analyst who prepared the report must certify that
Certifications-
• Opinions documented in the research report regarding the subject company or
sector are her own,
• Payment was not received that would have influenced his or her opinion. The
firm should document and maintain the basis upon which compensation was
established.
Control Issues-Information barriers separating research and investment banking
Issues-
communications must be reinforced through the supervision of these areas and
referenced in the supervisory procedures.
• The Research distribution department verifies a weekly report “watch list”
issued by compliance (in Moscow) to ensure research is not distributed during
a restricted period.
Required Approvals- Research distributed to clients in the US must be approved by
Approvals-
a US registered supervisor for compliance with appropriate US regulations.
• This is accomplished by a weekly e-mail is sent by the Head of Global Research
(US Series 24 & 87 Securities Principal) to the NY CCO stating review and
approval for the attached research reports.
Research
Research Employees visiting the US-All research staff (and non-US associated
US-
personnel) prior to meeting with US Institutional Investors must complete:
• “Foreign Associated Questionnaire” ,
• “Consent to Service of Process Form”
If these documents are already on file the analyst may attest via e-mail that the
data currently on file is correct and has not changed. In addition, a US registered
sales associate will chaperone all visits with US clients. Additionally both the:
• Research material distributed, (typically PowerPoint) and
• The formal agenda
All these documents are to be maintained in a central file by the analyst name.
Insider Trading Education & Attestations: Upon hire and no less than annually
Attestations:
thereafter all registered Troika Dialog USA, Inc employees will receive
• insider trading continuing education
• sign an attestation that states the employee understands and will comply with
the policy
2711 Certification- The 2711 Certification is required for firms that produce or
Certification-
distribute research reports. This filing is used by a senior officer of the member
firm to attest annually by April 1st of each year that it has adopted and
implemented written supervisory procedures reasonably designed to ensure that
the member and its employees comply with the provisions of Rule 2711.