SEC Gives Interpretive Guidance On Global Research Analyst Settlement

November 9, 2004

Responding to a Cleary Gottlieb request, the SEC’s Division of Market Regulation staff has issued interpretive guidance on various aspects of the Global Research Analyst Settlement. Cleary Gottlieb made the request on behalf of the 12 major investment banking firms involved in the settlement. The letter clarifies a number of settlement topics, including communications between analysts and investment bankers, communications about covered companies, participation in conferences, analyst compensation, and chaperoning requirements. The firm advised the 12 banks in the discussions, which resulted in the letter being issued.