Willier is the research analyst responsible for following Company X. All the information he has accumulated and documented suggest that the outlook for the firm’s new products is poor, so the stock should be rated a weak hold. During lunch, however, Willier overhears a financial analyst from another firm offer opinions that conflict with Willier’s forecasts and expectations. Upon returning to his office, Willier releases a strong buy recommendation to the public. Willier:

Willier is the research analyst responsible for following Company X. All the information he has accumulated and documented suggest that the outlook for the firm’s new products is poor, so the stock should be rated a weak hold. During lunch, however, Willier overhears a financial analyst from another firm offer opinions that conflict with Willier’s forecasts and expectations. Upon returning to his office, Willier releases a strong buy recommendation to the public. Willier:

A. violated the Standards by failing to distinguish between facts and opinions in his recommendation.

B. was in full compliance with the Standards.

C. violated the Standards because he did not have a reasonable and adequate basis for his recommendation.

D. violated the Standards because he did not seek approval of the change from his firm’s compliance department.

Answer: C

Explanation:

The question deals with Standard IV (A.1), Reasonable Basis and Representations. Willier’s actions in changing the recommendation based on the opinion of another financial analyst is not an adequate basis for the recommendation. This question does not illustrate a violation of the need to distinguish between facts and opinions. Seeking approval from the firm for a change in a recommendation is a matter of policy set by the firm, not by the Standards.

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