3. Limit the number of access persons. “Fire Walls” should be built to prevent the flow of information from one group or department to other groups within the firm.

　　4. Define prohibited transactions. The text specifically mentions equity based IPOs.

　　5. Establish reporting procedures and prior-clearance requirements.

　　6. Ensure that procedures will be enforced and establish disciplinary procedures.

　　IV(B.5) Preservation of Confidentiality: Members shall preserve the confidentiality of information communicated by clients, prospects, or employers concerning matters within the scope of the client-member, prospect-member, or employer-member relationship unless the member receives information concerning illegal activities on the part of the client, prospect, or employer.

　　Compliance: The simplest and most effective way to comply is to avoid discussing any information received from a client except to colleagues working on the same project.

　　IV(B.6) Prohibition against Misrepresentation: Members shall not make any statements, orally or in writing that misrepresent:

　　a. the services that they or their firms are capable of performing.

　　b. their qualifications or the qualifications of their firm.

　　c. the member's academic or professional credentials.

　　Members shall not make or imply, orally or in writing, any assurances or guarantees regarding any investment except to communicate accurate information regarding the terms of the investment instrument and the issuer's obligations under the instrument.

　　Compliance: Firms can provide guidance to employees who make written or oral presentations to clients or prospects by providing a written list of the firm’s available services and a description of the firm’s qualifications.

　　IV(B.7) Disclosure of Conflicts to Clients and Prospects: Members shall disclose to their clients and prospects all matters, including beneficial ownership of securities or other investments, that reasonably could be expected to impair the member's ability to make unbiased and objective recommendations.

　　Compliance: Members should report to their employers, clients, and prospects any material beneficial interest they may have in securities, corporate directorships, or other special relationships they may have with the companies they are recommending. Members should make the disclosures before they make any recommendations or take any investment actions regarding these investments.