What is meant by “maintaining adequate internal regulations within the J-Nomad to avoid … conflicts of interest”?
A conflict of interest would refer to, for instance, the use of information obtained through J-Nomad duties to profit in some other area of the J-Nomad firm. “Adequate internal regulations” refers to appropriate safeguards, depending on the size and structure of the J-Nomad firm, to prevent conflict of interest from arising. Examples include implementing information barriers (1) on a large scale, between the IPO department and the trading department; (2) within the IPO department, between the IPO executory section and other sections; and (3) within the IPO executory section, between the J-Qualified Executive and all other members.
