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Question:
Black is in possession of material nonpublic information, and her most appropriate course of action is to inform her supervisor (or the firms compliance officer) of what she has learned. She may not simply share the information with prospective buyers; if her firm determines that the information affects the value of the debentures, they must revise and recirculate the prospectus. Failing to do so may violate Standard 1(C) Misrepresentation. Not informing her employer may be detrimental to her firm’s interests and reputation if proceeding with the new issue without disclosure would violate regulations or laws.
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