2) Some analyst compile了一些public的信息,再加上他从suppiler, customers等收集到的piece information 然后得到结论某stock要涨, 于是乎he bought some shares from several accounts. 后来他在某场合overhear到一些material nonpublic的确切要涨的信息, 然后he bought some additional shares for his clients.
我选的答案是: initial purchasing violates “Fair dealing” but not “material nonpublic”, because he got his conclusion based on Mosaic theory. However he violates “Fair dealing” because he only bought it from several accounts. It doesn’t say he bought it from the accounts for which it is appropriate”
The additional purchasing violates “material nonpublic” because his trading is based on some material nonpublic information that he overheard.