Propose practices and procedures that stop breaches of the ethics Code and the Standards of Professional Conduct before they occur

The central control is an information barrier: interdepartmental communication cleared through compliance or legal, watch, restricted and rumour lists, written documentation of procedures and of enforcement, and tighter review of proprietary trading while the firm holds inside information. Staff should sit on one side of the wall at a time, and an analyst brought over it stays there until the information is public. A member who receives inside information should first urge the company to make it public and tell compliance, never trade. Against manipulation, firms should monitor for orders placed near the close, orders cancelled before execution, trades with no change of ownership and coordinated activity, and should review what staff publish about securities.