An analyst combines an issuer's public 10-K, published industry shipment data, and impressions from a tour of a public showroom to conclude the stock is undervalued, then recommends it. Why is this conduct generally permissible?
- AA recommendation is permissible only if the analyst also files the conclusion with the SEC first
- BAny information an analyst personally gathers automatically becomes public
- CThe analyst reached a conclusion by assembling individually public pieces of information rather than trading on any single piece of material nonpublic informationcorrect
- DAnalysts are statutorily exempt from the insider-trading rules
Why C is correct
The mosaic theory allows an analyst to combine separate items of public information to form a non-public conclusion; this is legitimate analysis, not insider trading, because no material nonpublic information was used.
