INMA S4.2 Investment research recommendation — general standards for disclosure of interests etc

(1) An INMA firm must disclose, in a research recommendation produced by it:
(a) all of its relationships and circumstances that may reasonably be expected to impair the objectivity of the research recommendation, and in particular:
(i) any significant financial interest in a relevant investment that is the subject of the research recommendation;
(ii) a significant conflict of interest in relation to an issuer; and
(b) relationships and circumstances, of the kind mentioned in paragraph (a), of each person working for the firm who was involved in preparing the substance of the research recommendation, including whether the person's [individual's?] remuneration is tied to investment banking transactions performed by the firm or any affiliate of the firm.
(2) If the INMA firm is a legal person, the information disclosed must include the following:
(a) any interests or conflicts of interest of the firm or any related person that are accessible, or reasonably expected to be accessible, to the persons involved in the preparation of the substance of the research recommendation;
(b) any interests or conflicts of interest of the firm or any related person known to persons who, although not involved in the preparation of the substance of the research recommendation, had or could reasonably be expected to have had access to the substance of the research recommendation before its dissemination (other than persons whose only access to the research recommendation was to ensure compliance with relevant regulatory or statutory obligations, including the disclosures required under this Schedule).
(3) If the disclosures required by subrules (1) and (2) would be disproportionate to the length of the research recommendation, the INMA firm may, instead of complying with the requirements of the subrules, clearly and prominently refer in the research recommendation to where the required disclosures can be directly and easily accessed (for example, by a hyperlink to the disclosures on an appropriate web page of the firm).
(4) Subrules (1) and (2) do not apply in relation to a non-written research recommendation to the extent that complying with them would be disproportionate to the length of the research recommendation.
Inserted by QFCRA RM/2019-4 (as from 1st January 2020).