LeCompte violated Requirement 6, Relationships with Subject Companies, by sharing the full research report with NanoMem. Sharing any section of a research report that might communicate the analyst’s proposed recommendation, rating, or price target is prohibited by the Research Objectivity Standards. Sharing historical factual information, on the other hand, is not a violation.
LeCompte shared with UniFlash management only the part of her report on UniFlash that provides factual information.

. LeCompte provided all the recommended disclosures relating to potential conflicts of interest with respect to UniFlash. In addition to her small equity position in NanoMem and the firm’s market making role for NanoMem shares, LeCompte should have also disclosed the “benefit received” from NanoMem concerning the trip she took as required by Standard 2, Public Appearances. In addition, if news of the secondary offering of NanoMem had already been made public, she should have also disclosed the fact that Topaz had been appointed the lead underwriter.
LeCompte only provided recommended disclosures relating to potential conflicts of interest with respect to UniFlash.

Swift’s functional currency is the AUD because sales are generated in AUD and the company operates within the competitive and regulatory environment of Australia. Under IFRS, when the subsidiary’s functional currency is the local currency, translations are done using the current rate method. Thus, Swift will use the current rate method for converting its financial statements.
The use of the current rate method depends on the identification of the functional currency, not on the local currency. Translations from the functional currency to the presentation currency is done using the current rate method. The local currency has an impact on translation only where it differs from the functional currency. In these cases, the translation from the local to the functional currency is done using the temporal method.
Swift’s functional currency is the AUD, not the USD, because sales are generated in AUD and the company operates within the competitive and regulatory environment of Australia. If it were the USD this answer would be correct.

. According to Standards I(B)–Independence and Objectivity and V(A)–Diligence and Reasonable Basis, members and candidates must exercise diligence, independence, objectivity, and thoroughness in analyzing investments, making investment recommen- dations, and taking investment actions. Changing a written recommendation to what a subject company desires is not acting diligently, independently, objectively, and/or thoroughly, and the analyst should immediately revise her recommendation to express her stated opinion of the company.
Changing a written recommendation to what a subject company desires is not acting diligently, independently, objectively, and/or thoroughly.

An HHI greater than 1,800 indicates that an industry is highly concentrated. Should the HHI in a highly concentrated industry change by 50 or more, a governmental challenge to a particular business combination is very likely. In this instance, the industry is highly concentrated and the HHI changes by 90, making Whelan’s second conclusion incorrect. A government challenge is likely.
Whelan’s second conclusion is not correct.
Whelan’s conclusion that the industry is highly concentrated is correct.