H2Oshinsky:
<<Other than disagreeing with your interpretation of what is and is not a research report, is there anything illegal about that report? >>
Not being a lawyer, I would not go that far at this point. It does appear that RAM left out the amount of compensation, which on the surface, seems to be in contravention of Section 17 of the Securities Act of 1933.
3.to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser.
b.It shall be unlawful for any person, by the use of any means or instruments of transportation or communication in interstate commerce or by the use of the
mails, to publish, give publicity to, or circulate any notice, circular, advertisement, newspaper, article, letter, investment service, or communication which,
though not purporting to offer a security for sale, describes such security for a consideration received or to be received, directly or indirectly, from an issuer,
underwriter, or dealer, without fully disclosing the receipt, whether past or prospective, of such consideration and the amount thereof. |
