Research Report Approval, Disclosures, and Dissemination
Chapters in this video
What this video covers
- Why the Series 16 Supervisory Analyst is the report-by-report gatekeeper, and why a Series 24 General Securities Principal alone cannot pre-publication approve research
- The four things a Supervisory Analyst actually reviews: factual basis, reasonable conclusions, analyst certifications, and communications-with-the-public compliance
- Why personal disagreement with an analyst's investment opinion is never valid grounds for refusing approval if the factual basis and disclosures are solid
- The 1% firm-wide beneficial-ownership threshold, and why it aggregates prop desk, affiliate, and error-account holdings for disclosure purposes
- The 12-month backward-looking window for investment banking compensation and managed or co-managed offerings, versus the 3-month forward-looking window for expected IB compensation
- Why pushing third-party research to a client triggers full principal review, while shelving it on a portal only requires source disclosure
- Why pre-publication tipping to internal desks is a per se violation, and why distribution tiers must be documented in official firm policy
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