What Is NOT Suggested as a Firm Policy?

A

Under the compliance procedures for Standard IV (B.4), members and their firms should clearly define prohibited transactions so that employees completely understand their obligations to clients and their employer. Participation by investment personnel in equity or equity-based IPOs should be restricted. Also, firm procedures should prevent managers or employees from initiating trades in a security for which their firms have a pending buy or sell order within a 24-hour period. Firms must determine specific requirements relating to such blackout periods. All individuals who are involved in the investment decisionmaking process should be subject to the same restricted period.