What conflicts put a company on the restricted list, vs which ones are ok to just put in a disclosure in a research report? My understanding is that if the firm is unwilling to give a negative (or positive) review because of e.g. an active deal, it goes on the restricted list, meaning facts-only, no recommendations. Further, any communication between firewalled departments is monitored/chaperoned by a compliance officer. If the author or anyone in the firm is personally linked (either by owning stock or serving on the covered company's board), it's ok to publish a recommendation, just with the respective disclosures. Anyone in the know, kindly confirm if the above is accurate. Thanks!

Restricted List vs. Acceptable for Disclosure