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Is a telephone interview between a research analyst and a member of the media considered a public appearance?

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Is a telephone interview between a research analyst and a member of the media considered a public appearance?

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The term “public appearance” means “any participation by a research analyst in a . . . radio or television or other interview in which the research analyst makes a specific recommendation or provides information reasonably sufficient upon which to base an investment decision about a security or an issuer.” (emphasis added). Participation by a research analyst in a telephone interview with a member of the media would be considered an “other interview” within the definition. Question 14: Regulation AC’s effective date, April 14, 2003, fell almost two weeks after the beginning of the second calendar quarter of 2003 (April 1 June 30). Rule 502 requires a broker-dealer to make a record in connection with a public appearance by a research analyst employed by the broker-dealer or covered person within thirty days after any calendar quarter in which the research analyst made a public appearance. For what period must broker-dealers make Rule 502 records for the second quarter of 2003? Answer: B

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