Institute Comments on Research Analyst Disclosure ProposalWashington, DC, April 22, 2002 - The Institute commented recently on proposed rule changes filed by NASD Regulation and the New York Stock Exchange to address research analysts' conflicts of interest. According to a comment letter recently submitted by the Institute, "sellside" analyst recommendations differ substantially from statements made by mutual fund portfolio managers. Therefore, the Institute supports the proposal to exclude mutual fund portfolio managers from the rule's definition of a research analyst. The Institute also notes that advisory firms already maintain stringent procedures to address potential conflicts relating to the personal investment activities of their investment personnel, including portfolio managers. In addition, the Institute's letter seeks clarification on: - the definition of a "research report," and
- the definition of the term "affiliate."
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