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While visiting Cassori Company, Mark Ramsey, CFA. overhears management make comments that are not public information but are not really meaningful by themselves. Combining this information with his own analysis and other outside sources, Ramsey decides to change his recommendation on Cassori from “Buy” to “Sell.” According to the CFA Institute Standards of Professional Conduct, Ramsey:

A may issue his “Sell” report because the facts are nonmaterial, but should maintain a file of the facts and documents leading to this conclusion.

According to Standard 11(A) Material Nonpublic Information, the use of security analysis combined with nonmaterial nonpublic information to arrive at significant conclusions is allowable under the mosaic theory.

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