Perez is CFO of a large retailer. He mentions during a round of golf with Smith, a local investment adviser and personal friend, that sales will be up this quarter 10% over current "street" estimates. The next day Smith initiates a purchase of a large stake in the local exchange traded retail fund for her personal account. Group of answer choices Smith did not violate the Code and Standards because she did not invest directly in the securities of the local retailer. Perez did not violate the Code and Standards because the comments made to Smith were not intended to solicit an investment in the retailer. Smith violated the Code and Standards by investing in the exchange traded fund that included the retailer.
Added by Jacob F.
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Perez, as CFO, disclosed non-public information about the retailer's expected sales increase to Smith during a casual conversation. This information is material and non-public. Show more…
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