An Investment Dealer is acting as manager for a large secondary offering of XYZ Inc. shares. The security is now on the firm's Restricted List. A portfolio manager from a major pension fund, who is a long-standing institutional client, calls their Registered Representative at the dealer with an order to purchase 100,000 shares of XYZ Inc. The client has not been in contact with the RR for several weeks. According to UMIR 7.7, how should the RR handle this order?

Question

Accepted Answer

Under UMIR 7.7(4)(c), a dealer-restricted person can execute a trade for a client during a restricted period, provided the order was not solicited. Since the client initiated the contact and the order was unsolicited, the RR can execute it.

Discussion