Self-Regulatory Organizations; Notice of Filing of Proposed Rule Changes by the New York Stock Exchange, Inc., and the National Association of Securities Dealers, Inc., To Prohibit Participation by a Research Analyst in a Road Show Related to an Investment Banking Services Transaction and To Require Certain Communications About an Investment Banking Services Transaction To Be Fair, Balanced and Not Misleading, 13061-13066 [E5-1161]
Download as PDF
Federal Register / Vol. 70, No. 51 / Thursday, March 17, 2005 / Notices
(A) Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
NSCC is proposing to amend Section
I(A)(3) of Addendum B and Addendum
I, Section I(3) of Addendum Q, and
Section I(2) of Addendum R of NSCC’s
Rules and Procedures concerning the
operational capability requirements of
applicants for membership.
NSCC’s current rules specify that an
applicant must ‘‘have adequate
personnel capable of handling
transactions with the Corporation
[NSCC] and adequate physical facilities,
books and records and procedures to
fulfill anticipated commitments to and
to meet the operational requirements of
the Corporation [NSCC].’’ NSCC
believes that these provisions may be
interpreted to impose upon NSCC an
obligation to make determinations with
respect to these particular aspects of
members’ operational capability. NSCC
ordinarily leaves such determinations to
the members’ designated examining
authorities. The operational capability
that NSCC ordinarily focused upon
during the application process is the
applicant’s ability to appropriately
communicate with NSCC; that is, the
applicant’s ability to input data to NSCC
and to receive output from NSCC on a
timely and accurate basis.
NSCC believes that it is appropriate to
clarify these sections of the rules so that
they reflect the practices of NSCC and
so that there will be no
misunderstandings as to their meaning.
The text of the above-referenced
sections of NSCC’s Rules would be
amended to delete references to
adequate personnel and adequate
facilities, books, and records that are
extraneous to the ability of applicants to
communicate with NSCC. In place,
these sections will state that an
applicant must ‘‘be able to satisfactorily
communicate with the Corporation
[NSCC] * * *.’’ NSCC will continue to
retain the right to examine any aspect of
an applicant’s or member’s business
pursuant to the provisions of NSCC Rule
15.
NSCC believes that the proposed rule
change is consistent with the
requirements of Section 17A of the Act 3
and the rules and regulations
thereunder applicable to NSCC because
the proposed rule change will clarify
NSCC’s rules and procedures with
regard to requirements imposed on
applicants for membership. By
eliminating a potential
misinterpretation of its membership
3 15
U.S.C. 78q–1.
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requirements, NSCC believes that it will
thereby provide enhanced protections to
NSCC and its members and will assist
NSCC in assuring the safeguarding of
funds and securities in NSCC’s control
or for which NSCC is responsible.
(B) Self-Regulatory Organization’s
Statement on Burden on Competition
NSCC does not believe that the
proposed rule change will have any
impact or impose any burden on
competition.
(C) Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants or Others
Written comments relating to the
proposed rule change have not yet been
solicited or received. NSCC will notify
the Commission of any written
comments received by NSCC.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Within thirty-five days of the date of
publication of this notice in the Federal
Register or within such longer period (i)
as the Commission may designate up to
ninety days of such date if it finds such
longer period to be appropriate and
publishes its reasons for so finding or
(ii) as to which the self-regulatory
organization consents, the Commission
will:
(A) By order approve such proposed
rule change or
(B) institute proceedings to determine
whether the proposed rule change
should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
13061
number should be included on the
subject line if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Section, 450 Fifth Street, NW.,
Washington, DC 20549. Copies of such
filing also will be available for
inspection and copying at the principal
office of NSCC and on NSCC’s Web site
at https://www.nscc.com/legal. All
comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–NSCC–2005–01 and should
be submitted on or before April 7, 2005.
For the Commission by the Division of
Market Regulation, pursuant to delegated
authority.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. E5–1164 Filed 3–16–05; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34—51358; File Nos. SRNYSE–2004–24; SR–NASD 2004–141]
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml) or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–NSCC–2005–01 on the
subject line.
Paper Comments
• Send paper comments in triplicate
to Jonathan G. Katz, Secretary,
Securities and Exchange Commission,
450 Fifth Street, NW., Washington, DC
20549–0609.
All submissions should refer to File
Number SR–NSCC–2005–01. This file
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Self-Regulatory Organizations; Notice
of Filing of Proposed Rule Changes by
the New York Stock Exchange, Inc.,
and the National Association of
Securities Dealers, Inc., To Prohibit
Participation by a Research Analyst in
a Road Show Related to an Investment
Banking Services Transaction and To
Require Certain Communications
About an Investment Banking Services
Transaction To Be Fair, Balanced and
Not Misleading
March 10, 2005.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
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Federal Register / Vol. 70, No. 51 / Thursday, March 17, 2005 / Notices
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on April 22,
2004 the New York Stock Exchange
(‘‘NYSE’’ or the ‘‘Exchange’’), and on
September 20, 2004, the National
Association of Securities Dealers, Inc.
(‘‘NASD’’), filed with the Securities and
Exchange Commission (‘‘SEC’’ or
‘‘Commission’’) the proposed rule
changes as described in Items I, II, and
III below, which items have been
prepared by the respective selfregulatory organizations (‘‘SROs’’). On
February 11, 2005, NYSE filed
Amendment No. 1 to its proposed rule
change, which replaced the original rule
filing in its entirety. On February 4,
2005, NASD filed Amendment No. 1 to
its proposed rule change, which
replaced the original rule filing in its
entirety.3 The Commission is publishing
this notice to solicit comments on the
proposed rule changes, as amended,
from interested persons.
I. Self-Regulatory Organizations’
Statements of the Terms of Substance of
the Proposed Rule Changes
The Exchange is filing with the
Commission a proposed amendment to
NYSE Rule 472 (‘‘Communications with
the Public’’) which, among other things,
will prohibit research analysts from
participating in road shows relating to
investment banking services
transactions.
NASD is proposing a rule change to
NASD Rule 2711 to prohibit: (1) A
research analyst from participating in a
road show related to an investment
banking services transaction, or
otherwise communicating with
customers in the presence of investment
banking personnel or company
management about an investment
banking services transaction; and (2)
investment banking personnel from
directing a research analyst to engage in
sales and marketing efforts or other
communications with a current or
prospective customer related to an
investment banking services transaction.
The proposed rule change would permit
analysts to educate investors and
internal personnel about an investment
banking services transaction, provided
such communications are fair, balanced
and not misleading. Amendment No. 1
to the proposed rule change makes
express in the rule language the
requirement that those communications
be fair and balanced.
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 On March 9, 2005, NASD filed with the
Commission Amendment No. 2 to its proposed rule
change, which clarified that Amendment No. 1
replaced the original filing in its entirety.
2 17
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Below is the text of the proposed rule
changes. Proposed new language is
italicized.
A. NYSE’s Proposed Rule Text
Rule 472. Communications With the
Public Approval of Communications
and Research Reports
(a)(1)–(b)(5)—No change.
Investment Banking, Research
Department and Subject Company
Relationships and Communications
(b)(6)(i) A research analyst is
prohibited from directly or indirectly:
(a) participating in a road show
related to an investment banking
services transaction; and
(b) engaging in any communication
with a current or prospective
customer(s) in the presence of
investment banking department
personnel or company management
about an investment banking services
transaction.
(ii) Investment banking department
personnel are prohibited from directly
or indirectly:
(a) directing a research analyst to
engage in sales or marketing efforts
related to an investment banking
services transaction; and
(b) directing a research analyst to
engage in any communication with a
current or prospective customer(s) about
an investment banking services
transaction.
(iii) Research analyst written and oral
communications relating to an
investment banking services transaction,
with a current or prospective
customer(s), or with internal personnel,
must be fair, balanced and not
misleading, taking into consideration
the overall context in which the
communication is made.
(c)–.120—No change.
B. NASD’s Proposed Rule Text
Rule 2711. Research Analysts and
Research Report
(a) through (b) No change.
(c) Restrictions on Communications
with the Subject Company
(1) through (4) No change.
(5) A research analyst is prohibited
from directly or indirectly:
(A) participating in a road show
related to an investment banking
services transaction; and
(B) engaging in any communication
with a current or prospective customer
in the presence of investment banking
department personnel or company
management about an investment
banking services transaction.
(6) Investment banking department
personnel are prohibited from directly
or indirectly:
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(A) directing a research analyst to
engage in sales or marketing efforts
related to an investment banking
services transaction; and
(B) directing a research analyst to
engage in any communication with a
current or prospective customer about
an investment banking services
transaction.
(7) Any written or oral
communication by a research analyst
with a current or prospective customer
or internal personnel related to an
investment banking services transaction
must be fair, balanced and not
misleading, taking into consideration
the overall context in which the
communication is made.
(d) through (k) No change.
II. Self-Regulatory Organizations’
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In their filings with the Commission,
the Exchange and NASD included
statements concerning the purpose of,
and basis for, the proposed rule
changes, as amended, and discussed any
comments received on the proposed
rule changes. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange and NASD have prepared
summaries, set forth in sections (A), (B),
and (C) below, of the most significant
aspects of such statements.
(A) Self-Regulatory Organizations’
Statements of the Purpose of, and
Statutory Basis for, the Proposed Rule
Changes
1. NYSE’s Purpose
The Exchange is proposing an
amendment to NYSE Rule 472, which,
among other things, would prohibit
research analysts from participating in
road shows relating to investment
banking services 4 transactions.
Background
Joint regulatory efforts among the
NYSE, NASD (the ‘‘SROs’’) and the SEC
to address potential conflicts of interest
relating to research analysts resulted in:
(1) SEC approval of major SRO rule
4 As defined under Rule 472.20, ‘‘investment
banking services’’ includes, without limitation,
acting as an underwriter in an offering for the
issuer; acting as a financial adviser in a merger or
acquisition; providing venture capital, equity lines
of credit, PIPEs (private investment, public equity
transaction), or similar investments; or serving as
placement agent for the issuer. The term also
includes acting as a member of a selling group in
a securities underwriting (See NYSE Information
Memo No. 02–26, dated June 26, 2002).
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changes in May 2002; 5 (2) the adoption
of the Commission’s Regulation Analyst
Certification (‘‘Regulation AC’’),6 which
requires research analysts to certify that
their research reports accurately reflect
their personal views and disclose
whether they received compensation for
their specific recommendations; (3) the
Global Research Analyst Settlement
(‘‘Global Settlement’’) reached between
various securities regulators and 10
major investment banking firms to
conclude enforcement actions regarding
research analysts’ conflicts of interest; 7
and (4) additional changes to the SRO
Rules to conform to the Sarbanes-Oxley
Act,8 which were approved by the SEC
in July 2003 9 (the ‘‘Sarbanes-Oxley
Amendments’’).
Currently, according to the NYSE,
NYSE Rules 472 and 351 generally
restrict the relationship between
research and investment banking
departments and the companies that are
the subjects of research reports; require
disclosure of financial interests in
subject companies by analysts or
members or member organizations;
require disclosure of client relationships
with and compensation from subject
companies; impose quiet periods for the
issuance of research reports following
the completion of companies’ securities
offerings; restrict personal trading by
research analysts in the securities of the
companies covered by such analysts;
require attestations by members and
member organizations that they are in
compliance with NYSE Rule 472; and
generally require extensive disclosure in
research reports of certain important
information to help customers monitor
the correlation between research
analysts’ ratings and the price
movements of subject companies’
securities.
The Global Settlement
As noted above, the SEC, NYSE,
NASD, NASAA and the New York
Attorney General’s Office announced in
2003 a global settlement with 10
investment banking firms to settle
enforcement actions involving conflicts
of interest between research and
investment banking. The NYSE notes
that, among the undertakings included
in the settlement is a prohibition against
research analysts participating in efforts
5 See Securities Exchange Act Release No. 45908
(May 10, 2002), 67 FR 34969 (May 16, 2002) (SR–
NYSE–2002–09).
6 17 CFR 242.501.
7 See SEC Litigation Release No. 18438 (October
31, 2003).
8 15 U.S.C. 78o–6.
9 See Securities Exchange Act Release No. 48252
(July 29, 2003), 68 FR 45875 (August 4, 2003) (SR–
NYSE–2002–49).
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to solicit investment-banking business,
including attending ‘‘pitch’’ meetings.
According to the NYSE, these
restrictions were imposed to prevent
stock recommendations from being
tainted by efforts to obtain investment
banking fees, and to further remove
research analysts from investment
banking pressures.
In July 2003, the SEC approved the
Sarbanes-Oxley Amendments. At the
same time, the SEC also approved NYSE
Rule 472(b)(5), which prohibits research
analysts from participating in
solicitation activities (e.g., pitch
meetings) to secure investment banking
business from companies. During the
filing and public comment period, the
SEC requested comment on the SRO
proposed amendments in light of the
Global Settlement, and also noted that
although certain elements of the Global
Settlement were addressed by the SROs
in their proposed amendments (e.g.,
pitch meeting prohibitions), there were
differences as well.
Proposed Amendment
Proposed NYSE Rule 472(b)(6)
provides that:
(i) A research analyst is prohibited
from directly or indirectly:
(b) participating in a road show
related to an investment banking
services transaction; and
(c) engaging in any communication
with a current or prospective
customer(s) in the presence of
investment banking department
personnel or company management
about an investment banking services
transaction.
(ii) Investment banking department
personnel are prohibited from directly
or indirectly:
(a) directing a research analyst to
engage in sales or marketing efforts
related to an investment banking
services transaction; and
(b) directing a research analyst to
engage in any communication with a
current or prospective customer(s) about
an investment banking services
transaction.
(iii) Research analyst written and oral
communications relating to an
investment banking services transaction,
with a current or prospective
customer(s), or with internal personnel,
must be fair, balanced and not
misleading, taking into consideration
the overall context in which the
communication is made.
Discussion
The NYSE believes that underwriters
are the crucial intermediaries in the
process of offering securities to the
public. According to the NYSE, they
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13063
provide sales and marketing expertise to
issuers during the securities offering
process, and provide research coverage
for companies they help bring public.
The NYSE believes that since research
can impact the price of a company’s
securities, it is paramount to investor
protection, that such research be
objective, unbiased, and not the result of
pressure on an analyst. The NYSE notes
that such pressure can take the form of:
trying to reward a company for its
investment banking business, or to
assist a firm’s investment bankers in
obtaining and maintaining investment
banking relationships with a company.
The NYSE believes that to ensure this
goal, it is necessary to insulate research
analysts from these pressures.
According to the NYSE, the offering of
securities is divided into three time
periods: (1) Pre-filing, (2) waiting, and
(3) the post-effective period. Once a
company contemplates a public
offering, the time period preceding the
filing of the registration statement is
known as the pre-filing period. After the
filing of the registration statement with
the Commission, there is a statutory
waiting period prior to the effective date
of the registration statement. After the
effective date, sales of the securities can
take place.10 It is during this waiting
period that underwriters, with the
management of issuers, conduct road
shows for the purpose of marketing the
offering. Finally, there is the posteffective period that continues until the
distribution of securities has been
completed. It is during this period that
prospectus delivery requirements are
imposed, and restrictions on the
issuance of research reports, often
referred to as ‘‘quiet periods’’ occur.11
According to the NYSE, regulatory
investigations and examinations
revealed that research analysts were
subject to conflicts of interest when
their firms were offering investment
banking services to, and maintaining
investment banking relationships with,
corporate issuers. In this regard, the
NYSE notes that the investigations
found that investment banking firms
may have promised favorable research,
10 15
U.S.C. 77(h)a.
the effective date of the offering, section
2(a)(10) of the Securities Act of 1933 (the
‘‘Securities Act’’) (15 U.S.C. 77b(a)(10)) permits the
use of supplementary sales literature (i.e. research
reports) even if such literature does not conform to
or is contained in a statutory prospectus, meeting
the requirements of section 10 of the Securities Act
(15 U.S.C. 77j). The use of this supplementary sales
literature, or ‘‘free writing,’’ is limited in that prior
to or at the same time of receiving it, a person must
have received a Section 10(a) statutory prospectus.
Given this limitation, firms often wait until this
prospectus delivery requirement ceases before
issuing research reports.
11 After
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Federal Register / Vol. 70, No. 51 / Thursday, March 17, 2005 / Notices
specific research ratings, or price targets
as consideration or inducement for the
receipt of investment banking business.
Furthermore, the NYSE believes that
investment bankers and companies
reviewed research reports prior to their
publication, which often pressured
research analysts to write more
favorable reports on such companies
than an objective, unbiased analysis of
the company warranted.
According to the NYSE, it was in
response to this activity that the
Exchange and NASD promulgated the
rules noted above to address these
concerns. These rules expressly prohibit
members and member organizations
from offering favorable research, ratings
or price targets as consideration or
inducement for the receipt of
investment banking business.12 In
addition, the NYSE notes that rules
were promulgated to prevent research
analysts from being pressured to
provide favorable reports and ratings,
such as prohibiting investment banking
personnel from exercising supervision,
control and compensatory evaluation
over research analysts,13 and
prohibiting pre-publication review and
approval of research reports by
investment banking personnel and the
companies that are the subjects of such
reports.14
The NYSE notes that the rules also
prohibit research analysts from
participating in pitch meetings with
prospective investment banking
clients.15 According to the NYSE, the
purpose of this prohibition is to prevent
the use of research as a sales and
marketing tool, or to influence
prospective clients.
Further, the Exchange promulgated
restrictions on the publication and/or
distribution of research reports by
managers, co-managers, underwriters
and dealers following initial public 16
and secondary offerings 17 by issuers
and the expiration and/or waiver of
lock-up agreements made in connection
with such offerings.18 According to the
12 See
NYSE Rule 472(g)(1).
13 See NYSE Rule 472(b)(1).
14 See NYSE Rules 472(b)(2) and (4).
15 See NYSE Rule 472(b)(5).
16 As defined under Rule 472.100, an ‘‘initial
public offering’’ refers to the initial registered
equity security offering by an issuer, regardless of
whether such issuer is subject to the reporting
requirements of section 13 or 15(d) of the Securities
Exchange Act of 1934 (the ‘‘Exchange Act’’) (15
U.S.C. 78a), prior to the time of the filing of such
issuer’s registration statement.
17 As defined under Rule 472.110, a secondary
offering shall include a registered follow-on offering
by an issuer or a registered offering by persons other
than the issuer involving the distribution of
securities subject to Regulation M under the
Exchange Act.
18 See NYSE Rules 472(f)(1), (2), (3) and (4).
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NYSE, the purpose of these quiet period
restrictions was to minimize the ability
of firms to reward issuers for giving
them investment banking business by
publishing favorable research soon after
the completion of offerings.
As noted above, the Exchange
believes it has already adopted rules to
address inherent conflicts of interest
that arise when research analysts are
used by their firms to obtain, during the
waiting period, and reward, during the
post-effective period, issuers for their
investment banking business. According
to the NYSE, the proposed prohibition
on research analyst participation in road
shows seeks to address potential
conflicts of interest during the periods
that firms market securities offerings for
issuers. As proposed, the NYSE believes
that the new rule should insulate
research analysts from potential undue
influence of investment bankers and
company management, but not interfere
with legitimate activities.
By prohibiting analysts from engaging
in any communication regarding
investment banking services with
current or prospective customers in the
presence of investment banking
personnel or company management, the
Exchange believes it will reduce the
pressure on research analysts to give
overly optimistic assessments of
investment banking services
transactions. The NYSE believes that
research analysts would still be able to
communicate with customers in
circumstances where investment
banking and company management
cannot influence analysts’ truthful
assessments of investment banking
services transactions.
The Exchange is also proposing that
investment banking department
personnel be prohibited from directing
research analysts to: (1) Engage in sales
or marketing efforts related to
investment banking services
transactions; and (2) engage in
communications with current or
prospective customers about investment
banking services transactions.
According to the NYSE, the proposed
rule preserves the traditional function of
research analysts (providing analysis of
securities and transactions), while
placing further limitations on the ability
of investment banking personnel to
influence and/or compromise the
objectivity of their analysis.
While the proposed rule recognizes
that road shows are a common form of
investment banking ‘‘sales or marketing
efforts’’ from which research analysts
should be barred, the Exchange
recognizes there are certain activities
that do not compromise the objectivity
and independence of research analysts.
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Sfmt 4703
Therefore, the NYSE believes that the
proposed rule change would permit
research analysts to issue written and
oral communications relating to
investment banking services
transactions to current or prospective
customers or internal personnel.
According to the NYSE, such
communications to investors and
employees must be fair, balanced, and
not misleading, while taking into
consideration the overall context in
which such communications are made.
The Exchange also notes that the
proposed prohibition on research
analysts’ participation in road shows
would not prohibit certain analysts’
communications that are permitted
under the federal securities laws (i.e.
research reports issued in accordance
with Rules 137, 138 and 139 under the
Securities Act).19
The Exchange notes that, although the
proposed amendment incorporates, to
some extent, the substance of the
comparable sales or marketing
prohibitions found in the ‘‘Global
Settlement,’’ the Exchange is not filing
the proposed rule change simply to
conform to the Global Settlement, or to
address the differences between the
Global Settlement and NYSE rules. The
Exchange believes the proposed
amendment facilitates objective,
independent, and reliable research by
prohibiting research analysts employed
by all members and member
organizations from participating in road
shows. The Exchange expects the entire
securities industry and not just the
signatory firms to the Global Settlement
to benefit from this prohibition. The
NYSE believes that by further insulating
research analysts from the pressures
associated with obtaining and
maintaining investment banking
relationships, the proposed rule change
will engender more objective and
unbiased research on companies who
are the investment banking clients of
members and member organizations.
Effective Date
The Exchange believes that the
proposed amendment to NYSE Rule 472
should take effect 45 days after SEC
approval. As proposed, the Exchange
believes that the amendment does not
impose any new or substantive
requirements on members and member
organizations nor would it necessitate
the adoption of new systems and
procedures to ensure compliance.
Accordingly, the NYSE believes that 45
days is sufficient notice for firms to
comply with the new prohibition.
19 17
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2. NYSE’s Statutory Basis
The NYSE believes the statutory basis
for this proposed rule change is section
6(b)(5) 20 of the Exchange Act which
requires, among other things, that the
rules of the Exchange be designed to
prevent fraudulent and manipulative
acts and practices, to promote just and
equitable principles of trade, and in
general to protect investors and the
public interests. The NYSE believes
that, by prohibiting research analysts
from participating in road shows, the
potential for conflicts of interests that
could bias their research reports will be
mitigated and thus serve the investing
public by providing more objective
research on subject companies.
3. NASD’s Purpose
Over the past few years, NASD has
worked with the SEC and New York
Stock Exchange (NYSE) to implement a
series of rules to increase the objectivity
and reliability of research. NASD
believes that while the rules generally
foster objectivity through extensive
conflict of interest disclosure
requirements, they also prohibit certain
conduct to minimize the primary source
of biased research: the influences of
investment banking. To that end, NASD
Rule 2711 prohibits compensation paid
to analysts based on their contributions
to, or the success of, the investment
banking department. The rule further
prohibits analysts from participating in
efforts to solicit investment banking
business, including ‘‘pitches’’ to earn an
underwriting mandate for a securities
offering.
According to the NASD, the proposed
rule change would further fortify the
wall between investment banking and
research by prohibiting research
analysts from participating in a road
show related to an investment banking
services transaction and from
communicating with current or
prospective customers in the presence
of investment banking department
personnel or company management
about such an investment banking
services transaction. Additionally, the
proposed rule change would prohibit
investment banking personnel from
directing a research analyst to engage in
sales and marketing efforts and other
communications with a current or
prospective customer about an
investment banking services transaction.
NASD believes that the primary role
of a research analyst is to provide
unbiased analysis of companies and
transactions and to value securities
accurately. NASD further believes that
20 15
U.S.C. 78f(b)(5).
VerDate jul<14>2003
14:51 Mar 16, 2005
Jkt 205001
the objectivity and reliability of such
analysis can be compromised when a
research analyst is utilized to market
those same transactions and the sale of
such securities. Accordingly, by
prohibiting research analyst
participation in road shows, the
proposed rule change will further
reduce the pressure on research analysts
to give an overly optimistic assessment
of a particular transaction. NASD
believes it further will remove any
suggestion to investors in attendance
that the analyst will give positive
coverage to the issuer and that the
analyst endorses all of the views
expressed by the company or
investment banking department
personnel.
According to the NASD, the proposed
rule change would, however, permit
research analysts to educate investors
and member personnel about a
particular offering or other transaction,
provided the communication occurs
outside the presence of the company or
investment banking department
personnel. NASD believes that such
permissible communications to
investors and internal personnel must
be fair, balanced and not misleading,
taking into account the overall context
in which such communications are
made. Thus, NASD believes that the
proposed rule change preserves the
ability of the research analyst to give a
candid assessment of a transaction or
sale of securities—including investment
risks—in settings where the influences
of investment banking and client
pressure are minimized.
Finally, the proposed rule change
would prohibit investment banking
department personnel from directing a
research analyst to engage in sales or
marketing efforts and any other
communication with a current or
prospective customer about an
investment banking services transaction.
NASD believes this provision is
important to eliminate any attempt by
investment banking personnel to
pressure a research analyst to engage in
those communications, thereby further
insulating research analysts from
influences that could affect their
objectivity.
NASD specifically requests comment
on whether the proposed prohibitions
should extend to supervisors of research
analysts, directors of the research
department or others who have the
ability to influence the substance of
research reports.
NASD also notes that the settlement
of research analyst conflicts allegations
among NASD, NYSE, the SEC, state
regulators and twelve of the nation’s
largest investment banking firms
PO 00000
Frm 00059
Fmt 4703
Sfmt 4703
13065
(‘‘Global Settlement’’) contains a
prohibition similar to the proposed rule
change. NASD does not believe that
consistency with the Global Settlement
is itself a rationale for the proposed rule
change. However, in this instance,
NASD believes that the similar
proposed rule change will facilitate the
goal of more objective and reliable
research by all members, with the
ancillary benefit of rules consistency.
The effective date of the proposed
rule change will be 45 days following
Commission approval.
4. NASD’s Statutory Basis
NASD believes that the proposed rule
change is consistent with the provisions
of section 15A(b)(6) of the Act,21 which
requires, among other things, that NASD
rules must be designed to prevent
fraudulent and manipulative acts and
practices, to promote just and equitable
principles of trade, and, in general, to
protect investors and the public interest.
NASD believes that the proposed rule
change is consistent with the provisions
of the Act because it will reduce
conflicts of interest and thereby provide
investors with more reliable information
and also curtail the potential for
fraudulent and manipulative acts.
(B) Self-Regulatory Organizations’
Statement on Burden on Competition
The NYSE and NASD do not believe
that the proposed rule changes will
impose any burden on competition not
necessary or appropriate in furtherance
of the purposes of the Exchange Act.
(C) Self-Regulatory Organizations’
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants or Others
The NYSE and NASD have neither
solicited nor received written comments
on the proposed rule changes.
III. Date of Effectiveness of the
Proposed Rule Changes and Timing for
Commission Action
Within 35 days of the date of
publication of this notice in the Federal
Register or within such longer period (i)
as the Commission may designate up to
90 days of such date if it finds such
longer period to be appropriate and
publishes its reasons for so finding, or
(ii) as to which the NYSE and NASD
consents, the Commission:
(a) By order approve such proposed
rule change, or
(b) Institute proceedings to determine
whether the proposed rule change
should be disapproved.
21 15
E:\FR\FM\17MRN1.SGM
U.S.C. 78o–3(b)(6).
17MRN1
13066
Federal Register / Vol. 70, No. 51 / Thursday, March 17, 2005 / Notices
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
For the Commission, by the Division of
Market Regulation, pursuant to delegated
authority.22
J. Lynn Taylor,
Assistant Secretary.
[FR Doc. E5–1161 Filed 3–16–05; 8:45 am]
TERRITORY OF AMERICAN SAMOA, LIMITED TO MANU’A ISLANDS—Continued
BILLING CODE 8010–01–P
Businesses with Credit Available
Elsewhere .................................
Businesses & Small Agricultural
Cooperatives without Credit
Available Elsewhere ..................
Other (Including Non-Profit Organizations) with Credit Available
Elsewhere .................................
Businesses and Non-Profit Organizations without Credit Available Elsewhere .........................
Electronic Comments
SMALL BUSINESS ADMINISTRATION
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Numbers SR–NYSE–2004–24 and/or
SR–NASD–2004–141 on the subject
line.
[Disaster Declaration # 10068 and # 10069
Paper Comments
• Send paper comments in triplicate
to Jonathan G. Katz, Secretary,
Securities and Exchange Commission,
450 Fifth Street, NW., Washington, DC
20549–0609.
All submissions should refer to File
Numbers SR–NYSE–2004–24 and/or
SR–NASD–2004–141. This file number
should be included on the subject line
if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room, 450 Fifth Street, NW.,
Washington, DC 20549. Copies of such
filing also will be available for
inspection and copying at the principal
office of the NYSE and NASD. All
comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to the File
Numbers SR–NYSE–2004–24 and/or
SR–NASD–2004–141 and should be
submitted on or before April 7, 2005.
VerDate jul<14>2003
14:51 Mar 16, 2005
Jkt 205001
American Samoa Disaster # AS–00001
Disaster Declaration
U.S. Small Business
Administration.
ACTION: Notice.
AGENCY:
SUMMARY: This is a Notice of the
Presidential declaration of a major
disaster for the Territory of American
Samoa (FEMA—1582—DR), dated 03/
03/2005.
Incident: Tropical Cyclone Olaf,
including High Winds, High Surf, and
Heavy Rainfall.
Incident Period: 02/15/2005 through
02/21/2005.
DATES: Effective Date: 03/03/2005.
Physical Loan Application Deadline
Date: 05/02/2005.
EIDL Loan Application Deadline Date:
12/05/2005.
ADDRESSES: Submit completed loan
applications to: U.S. Small Business
Administration, Disaster Area Office 4,
P.O. Box 419004, Sacramento, CA
95841.
FOR FURTHER INFORMATION CONTACT: A.
Escobar, Office of Disaster Assistance,
U.S. Small Business Administration,
409 3rd Street, Suite 6050, Washington,
DC 20416.
SUPPLEMENTARY INFORMATION: Notice is
hereby given that as a result of the
President’s major disaster declaration
for Public Assistance Only on February
18, 2005, and subsequent amendment
adding Individual Assistance on 03/03/
2005, applications for disaster loans
may be filed at the address listed above
or other locally announced locations.
The following areas have been
determined to be adversely affected by
the disaster:
The Interest Rates are:
TERRITORY OF AMERICAN SAMOA,
LIMITED TO MANU’A ISLANDS
Percent
Homeowners with Credit Available
Elsewhere .................................
Homeowners without Credit Available Elsewhere .........................
PO 00000
22 17
CFR 200.30–3(a)(12).
Frm 00060
Fmt 4703
Sfmt 4703
5.875
2.937
Percent
6.000
4.000
4.750
4.000
The number assigned to this disaster
for physical damage is 100688 and for
economic injury is 100690.
(Catalog of Federal Domestic Assistance
Numbers 59002 and 59008)
Herbert L. Mitchell,
Associate Administrator for Disaster
Assistance.
[FR Doc. 05–5305 Filed 3–16–05; 8:45 am]
BILLING CODE 8025–01–P
SMALL BUSINESS ADMINISTRATION
[Disaster Declaration # 10070]
Arizona Disaster # AZ–00003 Disaster
Declaration
U.S. Small Business
Administration.
ACTION: Notice.
AGENCY:
SUMMARY: This is a Notice of the
Presidential declaration of a major
disaster for Public Assistance Only for
the State of ARIZONA (FEMA—1581—
DR) , dated 02/17/2005.
Incident: Severe Storms and Flooding.
Incident Period: 12/28/2004 through
01/12/2005.
DATES: Effective Date: 02/17/2005.
Physical Loan Application Deadline
Date: 04/18/2005.
ADDRESSES: Submit completed loan
applications to: U.S. Small Business
Administration, Disaster Area Office 1,
360 Rainbow Blvd. South 3rd Floor,
Niagara Falls, NY 14303.
FOR FURTHER INFORMATION CONTACT: A.
Escobar, Office of Disaster Assistance,
U.S. Small Business Administration,
409 3rd Street, Suite 6050, Washington,
DC 20416
SUPPLEMENTARY INFORMATION: Notice is
hereby given that as a result of the
President’s major disaster declaration on
02/17/2005, applications for Private
Non-Profit organizations that provide
essential services of a governmental
nature may file disaster loan
E:\FR\FM\17MRN1.SGM
17MRN1
Agencies
[Federal Register Volume 70, Number 51 (Thursday, March 17, 2005)]
[Notices]
[Pages 13061-13066]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E5-1161]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34--51358; File Nos. SR-NYSE-2004-24; SR-NASD 2004-141]
Self-Regulatory Organizations; Notice of Filing of Proposed Rule
Changes by the New York Stock Exchange, Inc., and the National
Association of Securities Dealers, Inc., To Prohibit Participation by a
Research Analyst in a Road Show Related to an Investment Banking
Services Transaction and To Require Certain Communications About an
Investment Banking Services Transaction To Be Fair, Balanced and Not
Misleading
March 10, 2005.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
[[Page 13062]]
(``Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is hereby given that
on April 22, 2004 the New York Stock Exchange (``NYSE'' or the
``Exchange''), and on September 20, 2004, the National Association of
Securities Dealers, Inc. (``NASD''), filed with the Securities and
Exchange Commission (``SEC'' or ``Commission'') the proposed rule
changes as described in Items I, II, and III below, which items have
been prepared by the respective self-regulatory organizations
(``SROs''). On February 11, 2005, NYSE filed Amendment No. 1 to its
proposed rule change, which replaced the original rule filing in its
entirety. On February 4, 2005, NASD filed Amendment No. 1 to its
proposed rule change, which replaced the original rule filing in its
entirety.\3\ The Commission is publishing this notice to solicit
comments on the proposed rule changes, as amended, from interested
persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ On March 9, 2005, NASD filed with the Commission Amendment
No. 2 to its proposed rule change, which clarified that Amendment
No. 1 replaced the original filing in its entirety.
---------------------------------------------------------------------------
I. Self-Regulatory Organizations' Statements of the Terms of Substance
of the Proposed Rule Changes
The Exchange is filing with the Commission a proposed amendment to
NYSE Rule 472 (``Communications with the Public'') which, among other
things, will prohibit research analysts from participating in road
shows relating to investment banking services transactions.
NASD is proposing a rule change to NASD Rule 2711 to prohibit: (1)
A research analyst from participating in a road show related to an
investment banking services transaction, or otherwise communicating
with customers in the presence of investment banking personnel or
company management about an investment banking services transaction;
and (2) investment banking personnel from directing a research analyst
to engage in sales and marketing efforts or other communications with a
current or prospective customer related to an investment banking
services transaction. The proposed rule change would permit analysts to
educate investors and internal personnel about an investment banking
services transaction, provided such communications are fair, balanced
and not misleading. Amendment No. 1 to the proposed rule change makes
express in the rule language the requirement that those communications
be fair and balanced.
Below is the text of the proposed rule changes. Proposed new
language is italicized.
A. NYSE's Proposed Rule Text
Rule 472. Communications With the Public Approval of Communications and
Research Reports
(a)(1)-(b)(5)--No change.
Investment Banking, Research Department and Subject Company
Relationships and Communications
(b)(6)(i) A research analyst is prohibited from directly or
indirectly:
(a) participating in a road show related to an investment banking
services transaction; and
(b) engaging in any communication with a current or prospective
customer(s) in the presence of investment banking department personnel
or company management about an investment banking services transaction.
(ii) Investment banking department personnel are prohibited from
directly or indirectly:
(a) directing a research analyst to engage in sales or marketing
efforts related to an investment banking services transaction; and
(b) directing a research analyst to engage in any communication
with a current or prospective customer(s) about an investment banking
services transaction.
(iii) Research analyst written and oral communications relating to
an investment banking services transaction, with a current or
prospective customer(s), or with internal personnel, must be fair,
balanced and not misleading, taking into consideration the overall
context in which the communication is made.
(c)-.120--No change.
B. NASD's Proposed Rule Text
Rule 2711. Research Analysts and Research Report
(a) through (b) No change.
(c) Restrictions on Communications with the Subject Company
(1) through (4) No change.
(5) A research analyst is prohibited from directly or indirectly:
(A) participating in a road show related to an investment banking
services transaction; and
(B) engaging in any communication with a current or prospective
customer in the presence of investment banking department personnel or
company management about an investment banking services transaction.
(6) Investment banking department personnel are prohibited from
directly or indirectly:
(A) directing a research analyst to engage in sales or marketing
efforts related to an investment banking services transaction; and
(B) directing a research analyst to engage in any communication
with a current or prospective customer about an investment banking
services transaction.
(7) Any written or oral communication by a research analyst with a
current or prospective customer or internal personnel related to an
investment banking services transaction must be fair, balanced and not
misleading, taking into consideration the overall context in which the
communication is made.
(d) through (k) No change.
II. Self-Regulatory Organizations' Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In their filings with the Commission, the Exchange and NASD
included statements concerning the purpose of, and basis for, the
proposed rule changes, as amended, and discussed any comments received
on the proposed rule changes. The text of these statements may be
examined at the places specified in Item IV below. The Exchange and
NASD have prepared summaries, set forth in sections (A), (B), and (C)
below, of the most significant aspects of such statements.
(A) Self-Regulatory Organizations' Statements of the Purpose of, and
Statutory Basis for, the Proposed Rule Changes
1. NYSE's Purpose
The Exchange is proposing an amendment to NYSE Rule 472, which,
among other things, would prohibit research analysts from participating
in road shows relating to investment banking services \4\ transactions.
---------------------------------------------------------------------------
\4\ As defined under Rule 472.20, ``investment banking
services'' includes, without limitation, acting as an underwriter in
an offering for the issuer; acting as a financial adviser in a
merger or acquisition; providing venture capital, equity lines of
credit, PIPEs (private investment, public equity transaction), or
similar investments; or serving as placement agent for the issuer.
The term also includes acting as a member of a selling group in a
securities underwriting (See NYSE Information Memo No. 02-26, dated
June 26, 2002).
---------------------------------------------------------------------------
Background
Joint regulatory efforts among the NYSE, NASD (the ``SROs'') and
the SEC to address potential conflicts of interest relating to research
analysts resulted in: (1) SEC approval of major SRO rule
[[Page 13063]]
changes in May 2002; \5\ (2) the adoption of the Commission's
Regulation Analyst Certification (``Regulation AC''),\6\ which requires
research analysts to certify that their research reports accurately
reflect their personal views and disclose whether they received
compensation for their specific recommendations; (3) the Global
Research Analyst Settlement (``Global Settlement'') reached between
various securities regulators and 10 major investment banking firms to
conclude enforcement actions regarding research analysts' conflicts of
interest; \7\ and (4) additional changes to the SRO Rules to conform to
the Sarbanes-Oxley Act,\8\ which were approved by the SEC in July 2003
\9\ (the ``Sarbanes-Oxley Amendments'').
---------------------------------------------------------------------------
\5\ See Securities Exchange Act Release No. 45908 (May 10,
2002), 67 FR 34969 (May 16, 2002) (SR-NYSE-2002-09).
\6\ 17 CFR 242.501.
\7\ See SEC Litigation Release No. 18438 (October 31, 2003).
\8\ 15 U.S.C. 78o-6.
\9\ See Securities Exchange Act Release No. 48252 (July 29,
2003), 68 FR 45875 (August 4, 2003) (SR-NYSE-2002-49).
---------------------------------------------------------------------------
Currently, according to the NYSE, NYSE Rules 472 and 351 generally
restrict the relationship between research and investment banking
departments and the companies that are the subjects of research
reports; require disclosure of financial interests in subject companies
by analysts or members or member organizations; require disclosure of
client relationships with and compensation from subject companies;
impose quiet periods for the issuance of research reports following the
completion of companies' securities offerings; restrict personal
trading by research analysts in the securities of the companies covered
by such analysts; require attestations by members and member
organizations that they are in compliance with NYSE Rule 472; and
generally require extensive disclosure in research reports of certain
important information to help customers monitor the correlation between
research analysts' ratings and the price movements of subject
companies' securities.
The Global Settlement
As noted above, the SEC, NYSE, NASD, NASAA and the New York
Attorney General's Office announced in 2003 a global settlement with 10
investment banking firms to settle enforcement actions involving
conflicts of interest between research and investment banking. The NYSE
notes that, among the undertakings included in the settlement is a
prohibition against research analysts participating in efforts to
solicit investment-banking business, including attending ``pitch''
meetings. According to the NYSE, these restrictions were imposed to
prevent stock recommendations from being tainted by efforts to obtain
investment banking fees, and to further remove research analysts from
investment banking pressures.
In July 2003, the SEC approved the Sarbanes-Oxley Amendments. At
the same time, the SEC also approved NYSE Rule 472(b)(5), which
prohibits research analysts from participating in solicitation
activities (e.g., pitch meetings) to secure investment banking business
from companies. During the filing and public comment period, the SEC
requested comment on the SRO proposed amendments in light of the Global
Settlement, and also noted that although certain elements of the Global
Settlement were addressed by the SROs in their proposed amendments
(e.g., pitch meeting prohibitions), there were differences as well.
Proposed Amendment
Proposed NYSE Rule 472(b)(6) provides that:
(i) A research analyst is prohibited from directly or indirectly:
(b) participating in a road show related to an investment banking
services transaction; and
(c) engaging in any communication with a current or prospective
customer(s) in the presence of investment banking department personnel
or company management about an investment banking services transaction.
(ii) Investment banking department personnel are prohibited from
directly or indirectly:
(a) directing a research analyst to engage in sales or marketing
efforts related to an investment banking services transaction; and
(b) directing a research analyst to engage in any communication
with a current or prospective customer(s) about an investment banking
services transaction.
(iii) Research analyst written and oral communications relating to
an investment banking services transaction, with a current or
prospective customer(s), or with internal personnel, must be fair,
balanced and not misleading, taking into consideration the overall
context in which the communication is made.
Discussion
The NYSE believes that underwriters are the crucial intermediaries
in the process of offering securities to the public. According to the
NYSE, they provide sales and marketing expertise to issuers during the
securities offering process, and provide research coverage for
companies they help bring public. The NYSE believes that since research
can impact the price of a company's securities, it is paramount to
investor protection, that such research be objective, unbiased, and not
the result of pressure on an analyst. The NYSE notes that such pressure
can take the form of: trying to reward a company for its investment
banking business, or to assist a firm's investment bankers in obtaining
and maintaining investment banking relationships with a company. The
NYSE believes that to ensure this goal, it is necessary to insulate
research analysts from these pressures.
According to the NYSE, the offering of securities is divided into
three time periods: (1) Pre-filing, (2) waiting, and (3) the post-
effective period. Once a company contemplates a public offering, the
time period preceding the filing of the registration statement is known
as the pre-filing period. After the filing of the registration
statement with the Commission, there is a statutory waiting period
prior to the effective date of the registration statement. After the
effective date, sales of the securities can take place.\10\ It is
during this waiting period that underwriters, with the management of
issuers, conduct road shows for the purpose of marketing the offering.
Finally, there is the post-effective period that continues until the
distribution of securities has been completed. It is during this period
that prospectus delivery requirements are imposed, and restrictions on
the issuance of research reports, often referred to as ``quiet
periods'' occur.\11\
---------------------------------------------------------------------------
\10\ 15 U.S.C. 77(h)a.
\11\ After the effective date of the offering, section 2(a)(10)
of the Securities Act of 1933 (the ``Securities Act'') (15 U.S.C.
77b(a)(10)) permits the use of supplementary sales literature (i.e.
research reports) even if such literature does not conform to or is
contained in a statutory prospectus, meeting the requirements of
section 10 of the Securities Act (15 U.S.C. 77j). The use of this
supplementary sales literature, or ``free writing,'' is limited in
that prior to or at the same time of receiving it, a person must
have received a Section 10(a) statutory prospectus. Given this
limitation, firms often wait until this prospectus delivery
requirement ceases before issuing research reports.
---------------------------------------------------------------------------
According to the NYSE, regulatory investigations and examinations
revealed that research analysts were subject to conflicts of interest
when their firms were offering investment banking services to, and
maintaining investment banking relationships with, corporate issuers.
In this regard, the NYSE notes that the investigations found that
investment banking firms may have promised favorable research,
[[Page 13064]]
specific research ratings, or price targets as consideration or
inducement for the receipt of investment banking business. Furthermore,
the NYSE believes that investment bankers and companies reviewed
research reports prior to their publication, which often pressured
research analysts to write more favorable reports on such companies
than an objective, unbiased analysis of the company warranted.
According to the NYSE, it was in response to this activity that the
Exchange and NASD promulgated the rules noted above to address these
concerns. These rules expressly prohibit members and member
organizations from offering favorable research, ratings or price
targets as consideration or inducement for the receipt of investment
banking business.\12\ In addition, the NYSE notes that rules were
promulgated to prevent research analysts from being pressured to
provide favorable reports and ratings, such as prohibiting investment
banking personnel from exercising supervision, control and compensatory
evaluation over research analysts,\13\ and prohibiting pre-publication
review and approval of research reports by investment banking personnel
and the companies that are the subjects of such reports.\14\
---------------------------------------------------------------------------
\12\ See NYSE Rule 472(g)(1).
\13\ See NYSE Rule 472(b)(1).
\14\ See NYSE Rules 472(b)(2) and (4).
---------------------------------------------------------------------------
The NYSE notes that the rules also prohibit research analysts from
participating in pitch meetings with prospective investment banking
clients.\15\ According to the NYSE, the purpose of this prohibition is
to prevent the use of research as a sales and marketing tool, or to
influence prospective clients.
---------------------------------------------------------------------------
\15\ See NYSE Rule 472(b)(5).
---------------------------------------------------------------------------
Further, the Exchange promulgated restrictions on the publication
and/or distribution of research reports by managers, co-managers,
underwriters and dealers following initial public \16\ and secondary
offerings \17\ by issuers and the expiration and/or waiver of lock-up
agreements made in connection with such offerings.\18\ According to the
NYSE, the purpose of these quiet period restrictions was to minimize
the ability of firms to reward issuers for giving them investment
banking business by publishing favorable research soon after the
completion of offerings.
---------------------------------------------------------------------------
\16\ As defined under Rule 472.100, an ``initial public
offering'' refers to the initial registered equity security offering
by an issuer, regardless of whether such issuer is subject to the
reporting requirements of section 13 or 15(d) of the Securities
Exchange Act of 1934 (the ``Exchange Act'') (15 U.S.C. 78a), prior
to the time of the filing of such issuer's registration statement.
\17\ As defined under Rule 472.110, a secondary offering shall
include a registered follow-on offering by an issuer or a registered
offering by persons other than the issuer involving the distribution
of securities subject to Regulation M under the Exchange Act.
\18\ See NYSE Rules 472(f)(1), (2), (3) and (4).
---------------------------------------------------------------------------
As noted above, the Exchange believes it has already adopted rules
to address inherent conflicts of interest that arise when research
analysts are used by their firms to obtain, during the waiting period,
and reward, during the post-effective period, issuers for their
investment banking business. According to the NYSE, the proposed
prohibition on research analyst participation in road shows seeks to
address potential conflicts of interest during the periods that firms
market securities offerings for issuers. As proposed, the NYSE believes
that the new rule should insulate research analysts from potential
undue influence of investment bankers and company management, but not
interfere with legitimate activities.
By prohibiting analysts from engaging in any communication
regarding investment banking services with current or prospective
customers in the presence of investment banking personnel or company
management, the Exchange believes it will reduce the pressure on
research analysts to give overly optimistic assessments of investment
banking services transactions. The NYSE believes that research analysts
would still be able to communicate with customers in circumstances
where investment banking and company management cannot influence
analysts' truthful assessments of investment banking services
transactions.
The Exchange is also proposing that investment banking department
personnel be prohibited from directing research analysts to: (1) Engage
in sales or marketing efforts related to investment banking services
transactions; and (2) engage in communications with current or
prospective customers about investment banking services transactions.
According to the NYSE, the proposed rule preserves the traditional
function of research analysts (providing analysis of securities and
transactions), while placing further limitations on the ability of
investment banking personnel to influence and/or compromise the
objectivity of their analysis.
While the proposed rule recognizes that road shows are a common
form of investment banking ``sales or marketing efforts'' from which
research analysts should be barred, the Exchange recognizes there are
certain activities that do not compromise the objectivity and
independence of research analysts. Therefore, the NYSE believes that
the proposed rule change would permit research analysts to issue
written and oral communications relating to investment banking services
transactions to current or prospective customers or internal personnel.
According to the NYSE, such communications to investors and employees
must be fair, balanced, and not misleading, while taking into
consideration the overall context in which such communications are
made.
The Exchange also notes that the proposed prohibition on research
analysts' participation in road shows would not prohibit certain
analysts' communications that are permitted under the federal
securities laws (i.e. research reports issued in accordance with Rules
137, 138 and 139 under the Securities Act).\19\
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\19\ 17 CFR 230.137, 230.138 and 230.139.
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The Exchange notes that, although the proposed amendment
incorporates, to some extent, the substance of the comparable sales or
marketing prohibitions found in the ``Global Settlement,'' the Exchange
is not filing the proposed rule change simply to conform to the Global
Settlement, or to address the differences between the Global Settlement
and NYSE rules. The Exchange believes the proposed amendment
facilitates objective, independent, and reliable research by
prohibiting research analysts employed by all members and member
organizations from participating in road shows. The Exchange expects
the entire securities industry and not just the signatory firms to the
Global Settlement to benefit from this prohibition. The NYSE believes
that by further insulating research analysts from the pressures
associated with obtaining and maintaining investment banking
relationships, the proposed rule change will engender more objective
and unbiased research on companies who are the investment banking
clients of members and member organizations.
Effective Date
The Exchange believes that the proposed amendment to NYSE Rule 472
should take effect 45 days after SEC approval. As proposed, the
Exchange believes that the amendment does not impose any new or
substantive requirements on members and member organizations nor would
it necessitate the adoption of new systems and procedures to ensure
compliance. Accordingly, the NYSE believes that 45 days is sufficient
notice for firms to comply with the new prohibition.
[[Page 13065]]
2. NYSE's Statutory Basis
The NYSE believes the statutory basis for this proposed rule change
is section 6(b)(5) \20\ of the Exchange Act which requires, among other
things, that the rules of the Exchange be designed to prevent
fraudulent and manipulative acts and practices, to promote just and
equitable principles of trade, and in general to protect investors and
the public interests. The NYSE believes that, by prohibiting research
analysts from participating in road shows, the potential for conflicts
of interests that could bias their research reports will be mitigated
and thus serve the investing public by providing more objective
research on subject companies.
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\20\ 15 U.S.C. 78f(b)(5).
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3. NASD's Purpose
Over the past few years, NASD has worked with the SEC and New York
Stock Exchange (NYSE) to implement a series of rules to increase the
objectivity and reliability of research. NASD believes that while the
rules generally foster objectivity through extensive conflict of
interest disclosure requirements, they also prohibit certain conduct to
minimize the primary source of biased research: the influences of
investment banking. To that end, NASD Rule 2711 prohibits compensation
paid to analysts based on their contributions to, or the success of,
the investment banking department. The rule further prohibits analysts
from participating in efforts to solicit investment banking business,
including ``pitches'' to earn an underwriting mandate for a securities
offering.
According to the NASD, the proposed rule change would further
fortify the wall between investment banking and research by prohibiting
research analysts from participating in a road show related to an
investment banking services transaction and from communicating with
current or prospective customers in the presence of investment banking
department personnel or company management about such an investment
banking services transaction. Additionally, the proposed rule change
would prohibit investment banking personnel from directing a research
analyst to engage in sales and marketing efforts and other
communications with a current or prospective customer about an
investment banking services transaction.
NASD believes that the primary role of a research analyst is to
provide unbiased analysis of companies and transactions and to value
securities accurately. NASD further believes that the objectivity and
reliability of such analysis can be compromised when a research analyst
is utilized to market those same transactions and the sale of such
securities. Accordingly, by prohibiting research analyst participation
in road shows, the proposed rule change will further reduce the
pressure on research analysts to give an overly optimistic assessment
of a particular transaction. NASD believes it further will remove any
suggestion to investors in attendance that the analyst will give
positive coverage to the issuer and that the analyst endorses all of
the views expressed by the company or investment banking department
personnel.
According to the NASD, the proposed rule change would, however,
permit research analysts to educate investors and member personnel
about a particular offering or other transaction, provided the
communication occurs outside the presence of the company or investment
banking department personnel. NASD believes that such permissible
communications to investors and internal personnel must be fair,
balanced and not misleading, taking into account the overall context in
which such communications are made. Thus, NASD believes that the
proposed rule change preserves the ability of the research analyst to
give a candid assessment of a transaction or sale of securities--
including investment risks--in settings where the influences of
investment banking and client pressure are minimized.
Finally, the proposed rule change would prohibit investment banking
department personnel from directing a research analyst to engage in
sales or marketing efforts and any other communication with a current
or prospective customer about an investment banking services
transaction. NASD believes this provision is important to eliminate any
attempt by investment banking personnel to pressure a research analyst
to engage in those communications, thereby further insulating research
analysts from influences that could affect their objectivity.
NASD specifically requests comment on whether the proposed
prohibitions should extend to supervisors of research analysts,
directors of the research department or others who have the ability to
influence the substance of research reports.
NASD also notes that the settlement of research analyst conflicts
allegations among NASD, NYSE, the SEC, state regulators and twelve of
the nation's largest investment banking firms (``Global Settlement'')
contains a prohibition similar to the proposed rule change. NASD does
not believe that consistency with the Global Settlement is itself a
rationale for the proposed rule change. However, in this instance, NASD
believes that the similar proposed rule change will facilitate the goal
of more objective and reliable research by all members, with the
ancillary benefit of rules consistency.
The effective date of the proposed rule change will be 45 days
following Commission approval.
4. NASD's Statutory Basis
NASD believes that the proposed rule change is consistent with the
provisions of section 15A(b)(6) of the Act,\21\ which requires, among
other things, that NASD rules must be designed to prevent fraudulent
and manipulative acts and practices, to promote just and equitable
principles of trade, and, in general, to protect investors and the
public interest. NASD believes that the proposed rule change is
consistent with the provisions of the Act because it will reduce
conflicts of interest and thereby provide investors with more reliable
information and also curtail the potential for fraudulent and
manipulative acts.
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\21\ 15 U.S.C. 78o-3(b)(6).
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(B) Self-Regulatory Organizations' Statement on Burden on Competition
The NYSE and NASD do not believe that the proposed rule changes
will impose any burden on competition not necessary or appropriate in
furtherance of the purposes of the Exchange Act.
(C) Self-Regulatory Organizations' Statement on Comments on the
Proposed Rule Change Received From Members, Participants or Others
The NYSE and NASD have neither solicited nor received written
comments on the proposed rule changes.
III. Date of Effectiveness of the Proposed Rule Changes and Timing for
Commission Action
Within 35 days of the date of publication of this notice in the
Federal Register or within such longer period (i) as the Commission may
designate up to 90 days of such date if it finds such longer period to
be appropriate and publishes its reasons for so finding, or (ii) as to
which the NYSE and NASD consents, the Commission:
(a) By order approve such proposed rule change, or
(b) Institute proceedings to determine whether the proposed rule
change should be disapproved.
[[Page 13066]]
IV. Solicitation of Comments
Interested persons are invited to submit written data, views and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://
www.sec.gov/rules/sro.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File Numbers SR-NYSE-2004-24 and/or SR-NASD-2004-141 on the subject
line.
Paper Comments
Send paper comments in triplicate to Jonathan G. Katz,
Secretary, Securities and Exchange Commission, 450 Fifth Street, NW.,
Washington, DC 20549-0609.
All submissions should refer to File Numbers SR-NYSE-2004-24 and/or
SR-NASD-2004-141. This file number should be included on the subject
line if e-mail is used. To help the Commission process and review your
comments more efficiently, please use only one method. The Commission
will post all comments on the Commission's Internet Web site (https://
www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent
amendments, all written statements with respect to the proposed rule
change that are filed with the Commission, and all written
communications relating to the proposed rule change between the
Commission and any person, other than those that may be withheld from
the public in accordance with the provisions of 5 U.S.C. 552, will be
available for inspection and copying in the Commission's Public
Reference Room, 450 Fifth Street, NW., Washington, DC 20549. Copies of
such filing also will be available for inspection and copying at the
principal office of the NYSE and NASD. All comments received will be
posted without change; the Commission does not edit personal
identifying information from submissions. You should submit only
information that you wish to make available publicly. All submissions
should refer to the File Numbers SR-NYSE-2004-24 and/or SR-NASD-2004-
141 and should be submitted on or before April 7, 2005.
For the Commission, by the Division of Market Regulation,
pursuant to delegated authority.\22\
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\22\ 17 CFR 200.30-3(a)(12).
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J. Lynn Taylor,
Assistant Secretary.
[FR Doc. E5-1161 Filed 3-16-05; 8:45 am]
BILLING CODE 8010-01-P