Analysts are instructed to send emails and letters using senior bankers’ email accounts instead of their own to generate deal flow. Essentially impersonating senior bankers to source deals in their place with financial incentives for every EL signed and new client won. I’m uneasy about the compliance risks of using someone else’s identity for outreach and pushing aggressive cold-calling tactics which might violate regulatory standards (like FINRA Rule 2210). Has anyone seen something like this before, or have thoughts on how to handle these kinds of directives?
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