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Is a password-protected conference call or Webcast in which a research analyst participates with clients considered a public appearance?

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Is a password-protected conference call or Webcast in which a research analyst participates with clients considered a public appearance?

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Yes. Participation by a research analyst in a conference call or Webcast with clients, whether or not password-protected, is a public appearance under Regulation AC. However, consistent with the discussion in the Adopting Release about what communications constitute research reports, the staff would not consider such participation by a research analyst to be a public appearance if the conference call or Webcast is limited to a group of fewer than 15 persons.

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