Public Appearances and Regulation AC

What this video covers

• What counts as a public appearance under the research-analyst conflicts rule, including why podcasts, Twitter posts, and Reddit AMAs are covered while closed-door institutional meetings are not
• The 15-person carve-out: how to identify when a recommendation reaches fewer than 15 persons with no media representative present
• The four mandatory live disclosures during a public appearance: financial interest, material conflicts, investment banking (IB) compensation past 12 months, and expected IB compensation next 3 months
• Why disclosures must occur during the appearance itself and cannot be satisfied by follow-up tweets, website links, or producer chyrons
• The two Regulation AC certifications: the per-report certification for individual research reports and the quarterly public-appearance certification
• The 30-day quarterly certification deadline, the 3-year books-and-records retention rule with 2 years easily accessible, and the 120-day penalty-box disclosure triggered by a missed deadline
• How Regulation AC applies to third-party and foreign analysts when their reports are distributed to U.S. customers