Series 87 — Research Analyst Qualification Examination (Part II) Exam Blueprint
Practical exam blueprint for the FINRA Series 87 — Research Analyst Qualification Examination (Part II), focused on research rules, conflicts, disclosures, supervision, and regulatory judgment.
How to Use This Exam Blueprint
Use this checklist as a practical study map for the FINRA Series 87 — Research Analyst Qualification Examination (Part II), official exam code Series 87. The goal is not to memorize isolated rule names. The goal is to recognize what a research analyst, supervisor, compliance reviewer, or member firm may, must, or must not do in realistic research scenarios.
For each topic area, ask:
- Can I identify the regulatory issue quickly?
- Can I distinguish a research report from other communications?
- Can I spot conflicts of interest and required disclosures?
- Can I decide who may review, approve, influence, or distribute research?
- Can I apply restrictions to analyst conduct, public appearances, personal trading, and interactions with investment banking?
- Can I explain the compliance purpose behind the rule?
Exact official weights are not assumed here. Treat the areas below as readiness areas for final review and practice.
Topic-Area Readiness Table
| Readiness area | What to review | You are ready when you can… | Common red flags |
|---|---|---|---|
| Research analyst role and regulatory scope | Who is a research analyst, what counts as research activity, and how analyst rules apply within a FINRA member firm | Identify when a person, report, communication, or activity falls inside research-related rules | Treating every market comment as a formal research report, or missing when a communication effectively contains a recommendation |
| Research reports | Definition, content standards, recommendations, ratings, price targets, valuation methods, and required presentation | Decide whether a communication is a research report and identify required review or disclosure steps | Confusing sales material, market color, internal notes, and formal research reports |
| Conflicts of interest | Investment banking conflicts, firm conflicts, analyst conflicts, issuer relationships, ownership interests, compensation links, and rating distribution concerns | Spot conflicts and determine whether they require disclosure, restriction, escalation, or supervisory review | Assuming disclosure always cures prohibited conduct |
| Required disclosures | Firm, analyst, compensation, ownership, market-making, investment banking, ratings, price chart, and other conflict disclosures when applicable | Match a scenario fact to the disclosure issue it triggers | Memorizing disclosure categories without knowing what fact triggers each one |
| Analyst independence | Separation from investment banking, sales, trading, issuer pressure, client pressure, and management influence | Identify improper influence over research content, rating, price target, timing, or compensation | Allowing “factual review” to become pressure on conclusions |
| Prepublication review | Who may review a draft, what may be reviewed, legal/compliance role, supervisory approval, and recordkeeping | Determine when draft review is permitted, restricted, or must be routed through appropriate controls | Letting investment banking or the subject company approve research conclusions |
| Public appearances | Analyst TV, conferences, interviews, calls, webcasts, podcasts, social media, and live comments | Apply disclosure and conduct expectations outside a written report | Forgetting that public appearances can trigger conflict and recommendation issues |
| Personal trading | Analyst account restrictions, holdings, trades around research, front-running concerns, and preclearance | Spot problematic trades and determine whether preclearance, prohibition, disclosure, or escalation is needed | Focusing only on firm trading while ignoring analyst household or related accounts |
| Investment banking interactions | Pitch participation, solicitation, roadshows, due diligence, issuer communications, and internal communications | Separate permitted information gathering from prohibited involvement in banking solicitation or research influence | Allowing research to be used as an inducement for investment banking business |
| Quiet/restricted periods and offering-related limits | Research timing around offerings, issuer events, lockups, and other restrictions tested conceptually | Recognize when timing of publication or public appearance may be restricted | Memorizing stale timing rules without understanding the policy reason |
| Regulation AC | Analyst certification regarding views and compensation | Identify when certification is required and what the certification is meant to confirm | Treating certification as a general disclosure rather than an analyst attestation |
| Regulation FD and selective disclosure | Material nonpublic information, issuer communications, selective disclosure, and public dissemination | Decide how a research analyst should respond after receiving potential MNPI | Continuing analysis or publication without escalation |
| Insider trading and MNPI | Materiality, nonpublic status, tipping, trading, information barriers, restricted lists, and watch lists | Identify possession, misuse, or improper sharing of MNPI | Assuming information is usable because it came from a client, issuer, or colleague |
| Supervision and written procedures | Firm controls, principal approval, escalation, surveillance, training, and records | Choose the right supervisory response to a rule breach or high-risk situation | Treating supervision as only after-the-fact discipline |
| Third-party research | Independent, third-party, and distributed research; firm responsibilities when distributing external research | Determine when a member firm has review or disclosure responsibilities for outside research | Assuming outside research carries no firm responsibility |
| Debt and equity research distinctions | Different product contexts, issuer relationships, credit opinions, and conflicts | Apply the same conflict-control logic while noticing product-specific facts | Applying equity-only assumptions to every research scenario |
| Communications standards | Fair and balanced presentation, omission risk, exaggerated claims, projections, recommendations, and suitability-adjacent issues | Identify misleading or incomplete research communication | Focusing only on required legends and ignoring the substance of the message |
| Books, records, and documentation | Approvals, certifications, disclosure records, analyst accounts, supervisory reviews, and escalation evidence | Identify what documentation should exist after a research event | Knowing the rule outcome but not the recordkeeping implication |
| Ethics and professional conduct | Objectivity, integrity, client interest, issuer pressure, internal pressure, and reputational risk | Select the most conservative compliant action when facts are ambiguous | Choosing the business-friendly answer over the control-friendly answer |
High-Value Definitions to Control
These terms appear repeatedly in Series 87-style scenarios. You do not need only a dictionary definition; you need to know why the classification matters.
| Term or concept | Why it matters on the exam | Readiness prompt |
|---|---|---|
| Research analyst | Determines whether analyst conduct, compensation, trading, and certification rules apply | Can you identify covered individuals even when their title is not “research analyst”? |
| Research report | Triggers content, review, disclosure, certification, and distribution controls | Can you distinguish a research report from market commentary or sales communication? |
| Recommendation | Raises disclosure, conflict, suitability-adjacent, and fair-presentation issues | Can you identify an implied recommendation, not just an explicit buy/sell/hold call? |
| Subject company | Connects the report, issuer relationship, holdings, compensation, and conflicts | Can you identify the issuer or issuer group being discussed? |
| Investment banking services | Creates conflict, separation, and disclosure concerns | Can you spot indirect banking incentives or relationships? |
| Public appearance | Expands research obligations beyond written reports | Can you apply disclosure logic to an interview, conference, or webcast? |
| Material nonpublic information | Controls whether information may be used, shared, or traded on | Can you decide when to stop and escalate? |
| Information barrier | Separates sensitive functions and prevents misuse of information | Can you identify a breach or weakness in the barrier? |
| Restricted list / watch list | Helps control trading, research, or communication risks | Can you infer why a security may need heightened controls? |
| Analyst certification | Supports independence of views and compensation representation | Can you identify when a certification problem exists? |
| Third-party research | Raises distribution, disclosure, and responsibility questions | Can you determine whether the firm is adopting, distributing, or merely making available outside content? |
Research Report Readiness Checklist
You should be able to review a research communication and answer each question quickly.
Classification
- Is this a research report, market commentary, sales material, internal communication, public appearance, or issuer communication?
- Does it analyze an issuer, security, industry, sector, or investment thesis?
- Does it include an express or implied recommendation?
- Is it intended for distribution to clients, investors, the public, or only internal personnel?
- Is the audience retail, institutional, internal, issuer-facing, or mixed?
- Does the format matter: written report, email, slide deck, model update, call transcript, webcast, social media post, or conference remarks?
Content Standards
- Are statements fair, balanced, and not misleading?
- Are risks disclosed with enough prominence?
- Are assumptions behind projections or price targets clear?
- Is the valuation method or basis for the recommendation explained where relevant?
- Are facts separated from opinions?
- Are material limitations, uncertainties, and conflicts addressed?
- Are ratings or recommendations consistent with the firm’s rating system?
- Are charts, historical performance references, and price targets presented in a way that avoids cherry-picking?
Required Review and Approval
- Has the appropriate supervisory person reviewed or approved the report when required?
- Were legal or compliance personnel involved when conflicts, MNPI, issuer review, or offering-related issues were present?
- Were draft comments limited to permitted purposes?
- Were prohibited reviewers excluded from influencing conclusions?
- Was the final version controlled so that unauthorized changes could not be made after approval?
- Are approval records, drafts, comments, certifications, and disclosures retained as required by firm procedures?
Disclosure Mapping
For each fact in a research scenario, ask whether it creates a disclosure, restriction, or escalation issue.
| Scenario fact | Likely issue to consider | Candidate task |
|---|---|---|
| Firm has provided or seeks investment banking services for the issuer | Conflict of interest | Determine whether disclosure, restriction, or separation issue exists |
| Analyst owns securities of the subject company | Analyst conflict and personal trading concern | Determine disclosure and trading implications |
| Firm or affiliate owns a significant position | Firm conflict | Determine whether disclosure is required |
| Firm makes a market or has trading interest in the security | Trading conflict | Determine disclosure or control implication |
| Analyst compensation is linked to investment banking revenue | Independence and compensation issue | Identify prohibited or disclosable compensation concern |
| Issuer reviewed a draft | Prepublication review concern | Determine whether review was permitted and limited |
| Investment banking commented on rating or price target | Improper influence | Identify violation or escalation |
| Report issued near an offering or other restricted event | Timing restriction concern | Determine whether publication or appearance should be delayed or escalated |
| Report contains a price target | Basis and risk disclosure concern | Determine whether assumptions and valuation basis are adequately explained |
| Report changes rating after issuer pressure | Analyst independence issue | Identify improper influence and supervisory concern |
Conflicts of Interest Checklist
Series 87 scenarios often test whether you can recognize a conflict and choose the right control. A conflict may require disclosure, but some conflicts require more than disclosure.
Can You Spot These Conflicts?
- Investment banking relationship with the subject company
- Expected investment banking compensation
- Analyst participation in soliciting investment banking business
- Firm or affiliate ownership interest in the subject company
- Analyst personal holdings or related-account holdings
- Analyst compensation tied to specific banking transactions
- Pressure from issuer management to improve rating or price target
- Pressure from sales or trading to publish favorable research
- Pressure from large clients or institutional accounts
- Market-making or trading position conflicts
- Research issued around offering-related events
- Selective distribution of research to favored clients
- Inconsistent internal and external views
- Public appearance that omits required conflict information
- Third-party research distributed without appropriate review or disclosure
Conflict Response Matrix
| If the fact pattern shows… | First concern | Strong exam response |
|---|---|---|
| Business unit wants favorable research to win an issuer mandate | Research independence | Refuse influence, escalate, and preserve separation |
| Analyst is asked to attend a pitch meeting | Investment banking solicitation risk | Identify whether participation is prohibited or requires strict controls |
| Issuer asks to remove negative language | Issuer influence | Limit issuer review, involve compliance, and do not alter conclusions improperly |
| Analyst received MNPI during a due diligence call | Insider trading / Regulation FD issue | Stop, do not trade or publish based on it, escalate |
| Sales desk wants advance notice of a downgrade | Selective disclosure / misuse risk | Do not selectively disclose; follow controlled release procedures |
| Analyst wants to trade before report publication | Personal trading and front-running risk | Preclear or prohibit according to firm controls; escalate if suspicious |
| Firm distributes outside research | Third-party research responsibility | Determine review, disclosure, and adoption implications |
| Analyst appears on television discussing a covered issuer | Public appearance disclosure | Provide required disclosures and avoid misleading statements |
Analyst Independence and Influence Controls
Be ready for questions where the issue is not the final report but the process used to produce it.
Permitted vs. Problematic Conduct
| Conduct | Usually lower risk when… | Problematic when… |
|---|---|---|
| Factual review by issuer | Limited to verifying objective facts and controlled by compliance procedures | Issuer edits tone, rating, valuation, recommendation, or price target |
| Internal review by legal/compliance | Focused on legal, regulatory, factual, or disclosure issues | Used as a channel for business pressure |
| Investment banking input | Strictly controlled and not about conclusions or recommendations | Banking personnel influence timing, rating, target, or content |
| Analyst industry diligence | Uses public sources, permissible nonpublic information controls, and documented process | Analyst receives MNPI and continues without escalation |
| Management review | Limited to administrative or supervisory functions | Senior management pressures analyst due to issuer or revenue concerns |
| Sales feedback | Helps understand investor questions without dictating research | Sales directs analyst to publish favorable or unfavorable research for trading reasons |
Independence Prompts
- Who benefits if the rating changes?
- Who asked for the change?
- Was the request about factual accuracy or investment conclusion?
- Was compliance involved before information crossed a barrier?
- Was the analyst’s compensation, review, or promotion tied to a banking outcome?
- Was the research timing connected to an offering, pitch, roadshow, or client demand?
- Did anyone outside research receive advance notice of a material change?
- Does documentation show independent analysis?
Prepublication Review Decision Path
Use this decision path when a scenario asks whether a draft report may be reviewed or changed.
flowchart TD
A[Draft research report exists] --> B{Who wants to review it?}
B --> C[Research supervisor / legal / compliance]
B --> D[Subject company]
B --> E[Investment banking / sales / trading]
C --> F[Review for supervisory, legal, factual, disclosure, and compliance issues]
D --> G{Limited factual review under controls?}
G --> H[Yes: route through proper procedures]
G --> I[No: improper influence risk]
E --> J{Permitted purpose and controlled channel?}
J --> K[Yes: document and limit scope]
J --> L[No: escalate and prevent influence]
F --> M[Finalize approval, certification, disclosures, and records]
H --> M
K --> M
I --> N[Do not publish until resolved]
L --> N
Disclosure Readiness Table
Do not study disclosures as a memorized list only. Study the fact pattern that triggers each disclosure or concern.
| Disclosure or concern | Trigger facts to notice | Exam-ready action |
|---|---|---|
| Analyst financial interest | Analyst, household, or related account has position or exposure | Identify disclosure, trading, and independence issue |
| Firm financial interest | Firm or affiliate owns securities or has economic exposure | Identify firm conflict disclosure issue |
| Investment banking relationship | Firm provided, provides, or seeks investment banking services | Identify conflict and related disclosure or restriction |
| Compensation conflict | Analyst or firm compensation tied to issuer or banking relationship | Determine whether compensation is improper, disclosable, or both |
| Market-making / trading role | Firm trades, makes a market, or has relevant trading interest | Identify disclosure and conflict issue |
| Rating distribution | Firm uses ratings system across covered universe | Recognize need for clear rating meaning and distribution context |
| Price target | Report includes target price or valuation estimate | Identify basis, assumptions, risks, and timeframe issues |
| Public appearance disclosure | Analyst discusses issuer/security publicly | Identify oral, visual, or accompanying disclosure expectations |
| Prior inconsistent recommendation | Report changes rating or target materially | Identify need for clear rationale and controlled release |
| Third-party research conflicts | Outside provider or distributing firm has relationship or conflict | Determine review and disclosure responsibility |
Regulation AC Readiness
Regulation AC is commonly tested through analyst certification scenarios.
Can You Do This?
- Identify when an analyst certification issue exists.
- Explain that the certification relates to the analyst’s personal views.
- Recognize compensation-related certification issues.
- Distinguish certification from a generic conflict disclosure.
- Spot a problem when research language does not reflect the analyst’s actual view.
- Spot a problem when compensation is directly or indirectly tied to a specific recommendation or view.
- Recognize that certification supports analyst accountability and research independence.
Scenario Cues
| Scenario cue | What to think |
|---|---|
| “The analyst disagrees with the final rating but signs the report anyway” | Certification and independence problem |
| “Compensation was promised if the analyst helped win the mandate” | Compensation conflict and independence problem |
| “The report contains a certification, but the analyst did not review the final draft” | Certification reliability and supervisory issue |
| “The analyst’s view changed after pressure from banking” | Improper influence and certification concern |
| “The analyst appears publicly and repeats the view in the report” | Public appearance and certification/disclosure consistency |
Regulation FD, MNPI, and Insider Trading Checklist
A strong Series 87 candidate can stop a scenario at the moment information becomes sensitive.
Material Nonpublic Information Prompts
- Is the information specific enough to affect an investment decision?
- Is it about earnings, guidance, mergers, offerings, credit events, regulatory events, product developments, or management changes?
- Has the information been publicly disseminated?
- Did it come from the issuer, an insider, an investment banking colleague, a client, a consultant, or another restricted source?
- Was the analyst wall-crossed or subject to confidentiality?
- Could publication, trading, or tipping misuse the information?
- Should the security be placed on a restricted list or watch list?
- Should legal/compliance be contacted immediately?
Correct Responses to Potential MNPI
| If the analyst receives… | Do not… | Do… |
|---|---|---|
| Nonpublic earnings guidance from issuer management | Publish, trade, or tip others | Escalate to legal/compliance |
| Deal information from investment banking | Incorporate it into research | Follow information barrier and restricted-list procedures |
| Client rumor that may be material | Trade or selectively alert favored clients | Verify through proper channels and escalate if needed |
| Confidential due diligence information | Use it as a research edge | Follow wall-crossing and confidentiality controls |
| Publicly available information | Assume no analysis is needed | Confirm it is genuinely public and not combined with MNPI |
Personal Trading Readiness
Personal trading questions often test timing, access, and conflicts.
Can You Identify the Problem?
- Analyst buys before initiating favorable coverage.
- Analyst sells before publishing a downgrade.
- Analyst’s spouse trades in a covered issuer.
- Analyst trades during a restricted period.
- Analyst trades contrary to the recommendation without required approval or disclosure.
- Analyst receives shares in an issuer connected to research coverage.
- Analyst trades after learning of a pending rating change.
- Analyst uses another account to avoid surveillance.
- Analyst fails to report holdings.
- Analyst claims the trade is allowed because the report has not been published yet.
Personal Trading Decision Questions
| Question | Why it matters |
|---|---|
| Is the security covered by the analyst or research department? | Coverage increases conflict and front-running risk |
| Is a report, rating change, or price target change pending? | Pending research can make trading improper |
| Does the analyst possess MNPI? | Trading may be prohibited regardless of research status |
| Is the account beneficially owned or controlled by the analyst? | Related accounts may be covered by restrictions |
| Was preclearance required and obtained? | Failure to preclear can be a violation even if trade appears harmless |
| Is the trade consistent with the current recommendation? | Inconsistency may require disclosure, restriction, or explanation |
| Is the trade around an offering or restricted event? | Additional restrictions may apply |
Public Appearances and Media Checklist
Series 87 is not limited to written research. Analysts can create regulatory issues in live or informal settings.
Review These Formats
- Television or radio interview
- Webinar or webcast
- Industry conference
- Investor conference call
- Podcast
- Social media post
- Live chat or online forum
- Press interview
- Panel discussion
- Internal call later forwarded externally
Public Appearance Risk Table
| Fact pattern | Issue | Ready response |
|---|---|---|
| Analyst gives a strong buy recommendation on air | Recommendation and disclosure | Identify required conflict disclosures and fair presentation concerns |
| Analyst discusses issuer after receiving MNPI | Insider trading / Regulation FD risk | Do not disclose or use MNPI; escalate |
| Analyst mentions only upside case | Misleading communication | Include balanced risk discussion |
| Analyst changes view verbally before report release | Selective disclosure and supervision | Follow controlled communication and publication procedures |
| Analyst is paid by issuer for appearance | Conflict | Identify disclosure and independence issues |
| Analyst uses social media to preview downgrade | Selective disclosure and improper communication | Recognize prohibited or highly restricted conduct |
Investment Banking Interaction Checklist
Expect scenarios where business pressure is subtle.
High-Risk Interactions
- Analyst attends issuer pitch meeting.
- Analyst promises favorable coverage to help win business.
- Banking asks analyst to delay negative report.
- Banking asks to review a draft before publication.
- Analyst is evaluated by investment banking personnel.
- Analyst compensation is based on a specific banking transaction.
- Issuer complains to banking about an analyst’s rating.
- Banking passes issuer comments to analyst without controls.
- Research is used in marketing an offering.
- Analyst joins roadshow-like activities.
- Analyst receives confidential deal information.
Decision Table
| If the exam asks whether the analyst may… | Focus on… |
|---|---|
| Help win investment banking business | Research independence and solicitation restrictions |
| Attend a pitch | Whether analyst participation creates improper promise or influence |
| Speak with issuer management | Diligence purpose, MNPI risk, and issuer influence controls |
| Share draft research with banking | Prepublication review limits and compliance routing |
| Change rating after banking pressure | Improper influence, supervision, and documentation |
| Be paid for a transaction | Compensation conflict and independence rules |
Supervision, Procedures, and Records
The exam may ask for the best firm response, not only the analyst’s personal obligation.
Supervisory Controls to Know
- Written supervisory procedures for research activities
- Principal review and approval where required
- Legal/compliance review for conflicts and sensitive events
- Information barriers between research and investment banking
- Restricted and watch list procedures
- Personal trading surveillance
- Disclosure review and maintenance
- Analyst account and holdings monitoring
- Public appearance tracking
- Third-party research review procedures
- Training and certification processes
- Escalation procedures for MNPI, conflicts, and rule breaches
- Record retention for drafts, approvals, disclosures, certifications, and communications
“Best Supervisory Response” Prompts
When answers look similar, choose the response that:
- Stops ongoing risk.
- Escalates to the right control function.
- Prevents misuse of MNPI.
- Preserves analyst independence.
- Documents the decision.
- Corrects or withdraws misleading communication if necessary.
- Applies firm procedures consistently.
- Avoids relying only on after-the-fact disclosure.
Third-Party Research Checklist
Third-party research questions often test whether a member firm can avoid responsibility by saying, “We did not write it.”
Can You Do This?
- Distinguish internal research from third-party research.
- Identify whether the firm is distributing, adopting, endorsing, or merely making available the research.
- Recognize when review is required before distribution.
- Identify conflicts of the third-party provider.
- Identify conflicts of the distributing firm.
- Determine whether disclosures are needed.
- Spot misleading, incomplete, stale, or inconsistent third-party material.
- Recognize when supervisory procedures should block distribution.
Scenario Cues
| Scenario | What to check |
|---|---|
| Firm emails outside research to clients | Distribution responsibility and disclosure |
| Outside provider is paid by issuer | Conflict disclosure and reliability |
| Firm edits third-party research before sending | Adoption or endorsement risk |
| Report conflicts with firm’s own rating | Fairness, clarity, and supervision |
| Third-party report lacks risk discussion | Misleading communication concern |
| Firm selectively sends favorable third-party research | Fair dealing and communication standards |
Offering-Related and Restricted-Period Judgment
Avoid relying only on memorized timing. The exam can test whether you understand the reason for restrictions: research should not be used to condition the market improperly or support an offering in a conflicted way.
Review Questions
- Is the subject company involved in an offering?
- Is the firm participating in the offering?
- Is the research being issued before, during, or after an offering-related event?
- Is the analyst involved in solicitation, marketing, or roadshow activity?
- Is the report initiating, changing, or reiterating coverage?
- Is the public appearance connected to offering promotion?
- Are there lockup, quiet-period, or other timing restrictions to consider?
- Has compliance approved the timing and content?
Common Exam Pattern
| Fact pattern | Likely issue |
|---|---|
| Research report released near an underwriting | Offering-related research restriction |
| Analyst appears at an issuer-sponsored event during offering process | Public appearance and solicitation concern |
| Banking asks analyst to publish favorable note before deal launch | Improper influence and market conditioning |
| Research is delayed because of restricted list status | Proper control may be required |
| Analyst wants to discuss issuer after wall-crossing | MNPI and confidentiality issue |
Communications Standards Checklist
Research rules overlap with broader communication principles. A technically complete disclosure does not save a misleading report.
Can You Identify Problems in the Message?
- Exaggerated claims
- Promises or guarantees
- Unsupported price targets
- Selective use of favorable data
- Omission of material risks
- Unclear rating definitions
- Confusing time horizon
- Inconsistent recommendation and narrative
- Unbalanced discussion of upside and downside
- Misleading comparison to peers or indexes
- Stale information presented as current
- Projection without assumptions
- Opinion presented as fact
- Inadequate explanation of conflicts
Fair Presentation Prompts
| Ask yourself… | Why it matters |
|---|---|
| Would a reasonable investor understand the basis for the recommendation? | Supports fair and balanced research |
| Are risks as visible as benefits? | Prevents one-sided communication |
| Is the time horizon clear? | Avoids misleading short-term vs long-term interpretation |
| Is the valuation method understandable? | Supports price target credibility |
| Are conflicts prominent enough? | Prevents hidden-bias concerns |
| Does the report match the firm’s rating system? | Avoids inconsistent recommendations |
Scenario and Decision-Point Practice
Use these prompts to test exam judgment.
Scenario 1: Issuer Review
An analyst sends a draft report to issuer management. The issuer corrects a factual error and asks the analyst to remove a negative discussion of margin pressure.
Can you answer?
- Which part of the issuer’s response may be acceptable?
- Which part creates improper influence risk?
- Who should control communications with the issuer?
- What records should be retained?
- Should the analyst change the investment conclusion?
Scenario 2: Banking Pressure
Investment banking tells research that a negative report will harm a pending mandate and asks for a delay.
Can you answer?
- Is the issue content, timing, or both?
- Is disclosure enough?
- Who should be notified?
- What research independence principle is implicated?
- What would be the best supervisory response?
Scenario 3: Analyst Trading
An analyst plans to sell shares of a covered issuer before publishing a downgrade.
Can you answer?
- What makes the trade high risk?
- Does publication status matter?
- What account restrictions may apply?
- Should preclearance resolve the issue automatically?
- What records and escalation are expected?
Scenario 4: Public Interview
An analyst appears on a financial news program and recommends a covered company without mentioning firm conflicts.
Can you answer?
- Is this a public appearance?
- What disclosures may be relevant?
- Is the recommendation subject to fair-presentation standards?
- What if the analyst’s firm has an investment banking relationship?
- What if the analyst owns the stock?
Scenario 5: Possible MNPI
During a private call, issuer management tells the analyst that quarterly earnings will miss expectations. The analyst has not seen the information publicly reported.
Can you answer?
- Is the information potentially material?
- Is it nonpublic?
- Can the analyst publish a downgrade based on it?
- Can the analyst tell the trading desk?
- What is the correct escalation path?
Scenario 6: Third-Party Report
A member firm distributes a favorable report written by an outside provider that is paid by the subject company.
Can you answer?
- Is this third-party research?
- Does the issuer-paid relationship matter?
- What review or disclosure issues arise?
- Can the firm avoid responsibility because it did not write the report?
- Is the communication fair and balanced?
Common Weak Areas and Traps
| Trap | Why candidates miss it | How to fix it |
|---|---|---|
| Thinking disclosure cures everything | Some conduct is restricted or prohibited even if disclosed | Ask: “Is this allowed at all, or only disclosable?” |
| Missing public appearance obligations | Candidates focus only on written reports | Treat interviews, conferences, and social posts as testable communications |
| Confusing factual review with content approval | Issuer or banking comments may look harmless | Ask whether the comment changes analysis, rating, target, or tone |
| Ignoring timing | Report timing can be as important as content | Always check offering, pending report, rating change, and restricted-list facts |
| Overlooking related accounts | Personal trading is not limited to the analyst’s named account | Consider household, controlled, and beneficial ownership facts |
| Treating MNPI as a research input | Analysts often receive valuable nonpublic information | Stop, escalate, and do not trade or publish based on MNPI |
| Forgetting firm-level conflicts | Candidate focuses only on analyst conflicts | Check firm, affiliate, banking, market-making, and ownership facts |
| Misclassifying communications | The exam may test format and audience | Decide what the communication is before applying rules |
| Choosing business convenience over compliance | Plausible answers may protect revenue | Prefer independence, escalation, documentation, and investor protection |
| Memorizing rule names without application | Series 87 is scenario-heavy | Practice with “who, what, when, conflict, disclosure, restriction” analysis |
Artifact and Documentation Checks
Be ready to recognize what records or compliance artifacts should exist.
| Artifact | What it supports |
|---|---|
| Final research report | Approved content, disclosures, rating, target, and recommendation |
| Drafts and comments | Prepublication review history and influence controls |
| Analyst certification | Regulation AC-related accountability |
| Disclosure checklist | Conflict identification and required disclosures |
| Supervisory approval record | Evidence of required review |
| Restricted list / watch list entry | Control of MNPI, offering, or conflict risk |
| Personal trading preclearance record | Monitoring of analyst account activity |
| Analyst holdings report | Conflict and disclosure review |
| Public appearance log | Tracking of oral or live research communications |
| Third-party research review record | Distribution responsibility and disclosure controls |
| Escalation memo | Evidence of response to MNPI, conflict, or breach |
| Information barrier log | Control of sensitive information flows |
| Training acknowledgement | Firm procedure awareness |
Rapid “Can You Do This?” Checklist
Before test day, you should be able to do all of the following without notes.
- Define the practical scope of the FINRA Series 87 research analyst rules.
- Identify when a communication is likely a research report.
- Identify when a public statement is a public appearance.
- Spot investment banking conflicts in subtle fact patterns.
- Separate disclosure issues from prohibited-conduct issues.
- Determine when issuer review is limited to factual verification.
- Recognize improper analyst involvement in investment banking solicitation.
- Identify compensation arrangements that threaten independence.
- Apply Regulation AC certification logic.
- Respond correctly to potential MNPI.
- Apply Regulation FD concepts to issuer communications.
- Identify analyst personal trading problems.
- Recognize selective disclosure of pending research.
- Identify required conflict disclosures from scenario facts.
- Evaluate whether a research communication is fair and balanced.
- Recognize when a report’s price target needs a basis and risk explanation.
- Apply public appearance disclosure logic.
- Evaluate third-party research distribution issues.
- Identify supervisory and recordkeeping responsibilities.
- Choose escalation when facts show uncertainty, MNPI, or improper influence.
- Avoid answers that prioritize revenue generation over analyst independence.
Final-Week Review Plan
Five to Seven Days Out
- Rebuild your conflict-disclosure chart from memory.
- Review research report vs. public appearance vs. sales communication distinctions.
- Drill scenarios involving investment banking pressure.
- Drill scenarios involving issuer review of drafts.
- Review analyst compensation and evaluation restrictions.
- Review personal trading restrictions and related-account issues.
- Review Regulation AC and Regulation FD concepts.
- Review MNPI escalation steps.
- Practice mixed questions where more than one issue appears.
Three to Four Days Out
- Work timed sets focused on judgment, not just definitions.
- For each missed question, label the miss: definition, disclosure, restriction, supervision, timing, or MNPI.
- Re-read explanations for questions you answered correctly by guessing.
- Create a one-page list of “stop and escalate” triggers.
- Review public appearance and third-party research scenarios.
- Practice identifying the best supervisory response.
One to Two Days Out
- Stop adding new obscure material unless it fixes a repeated miss.
- Review your error log.
- Memorize your conflict trigger map.
- Review common traps.
- Do a final mixed set under exam-like timing.
- Focus on reading every fact: role, timing, audience, relationship, compensation, ownership, and information source.
Test-Day Mental Checklist
For every scenario, ask:
- What is the communication or conduct?
- Who is involved?
- Is there a research report, recommendation, or public appearance?
- Is there a conflict?
- Is disclosure required, or is conduct restricted/prohibited?
- Is MNPI involved?
- Is investment banking influencing research?
- Is analyst trading or compensation involved?
- Does supervision or recordkeeping appear in the answer choices?
- Which answer best protects independence, fairness, and compliance?
Practical Next Step
Use this checklist to diagnose weak areas, then practice mixed Series 87 scenarios that force you to choose between disclosure, restriction, escalation, supervision, and documentation. The highest-value practice is not memorizing isolated rule names; it is repeatedly identifying the regulatory issue hidden in the facts and selecting the most compliant response.