Information barriers are physical, technological and procedural controls that restrict confidential or material non-public information to personnel who have a legitimate need to know it. Their principal purpose is to prevent inappropriate disclosure or use of confidential information, including use in insider trading, research activity, corporate-finance transactions or client and proprietary trading. Option B accurately describes this function.
Effective barriers may include restricted electronic permissions, separate work areas, controlled document access, employee undertakings, watch or restricted lists, access records and formal procedures for bringing an employee “over the wall.” Dealers must also monitor the effectiveness of these controls and provide appropriate staff training.
Option A incorrectly suggests that information barriers are intended to obstruct legitimate operational coordination. Communication may continue when it is authorized and consistent with confidentiality requirements. Option C is too narrow because protecting proprietary trading strategies is not the central regulatory purpose of confidential-information containment. Option D is also incorrect: access is not reserved automatically for executives. It should be restricted to authorized individuals whose duties create a legitimate business requirement, regardless of organizational rank.
CIRO’s official guidance defines information barriers as physical and procedural methods of restricting confidential information to those who need it and requires dealers to maintain robust safeguards against misuse of inside information.
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