According to Standard VI(B), who qualifies as an "access person"?

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The designation of "access person" under Standard VI(B) refers to individuals within an organization who are privy to non-public information that could influence investment decisions. Being an access person typically means having access to information that is valuable and not available to the general public, which could potentially impact trading strategies or market activity.

A supervisory analyst reviewing research reports fits this definition because they likely have access to critical information that has not been disclosed to the public. This role often involves evaluating sensitive data that could affect the firm's investment strategies, thus categorizing them as an access person.

In contrast, individuals like the independent auditor, entry-level researcher, or data entry clerk typically do not fit the criteria due to their limited or non-confidential access to information. An independent auditor, while having access to financial data, usually operates under strict confidentiality and does not engage in trading based on that information. An entry-level researcher without access to private data would not have the necessary qualifications to be considered an access person, nor would a data entry clerk who primarily handles routine tasks without exposure to sensitive information.

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