Research Checklist Generic

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Compliance checklist regarding research rules 15-a6 reg. AC

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Research Checklist Generic

  1. 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.

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