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Goldman: Golden Rules for Not Laying 'Goldman Eggs'

April 25, 2011

Goldman Sachs has the know-how to succeed in the financial markets:  what to buy, when to buy, and when to sell.  Timely execution is critical.  Goldman also strives to be the best at ... etiquette.  How so?  The answer may be found in the footnotes to the financial crisis report released on 4/13 by the Senate Permanent Subcommittee on Investigations. - page 2,501, to be exact.  There, one can read about Goldman's United States Policies for the Preparation, Supervision, Distribution and Retention of Written And Electronic Communications, published in 2001.  Bloomberg/BusinessWeek points out that the primer is so intricate its title has two different styles for the word "and."  

Here are Goldman's "Golden Rules," courtesy of Bloomberg/BW, with translations offered by Clusterstock.com.  You're expected to commit them to memory.

    1. Goldman Rule:   "No matter what you are communicating to the public, your words reflect on the reputation of the firm. ... The firm, therefore, requires that your communication reflect the high standards of the firm, not only in what you say, but also in the way you say it."   [Translation:  Don't speak your mind. Speak the firm's mind.]

    2. Goldman Rule:  "The level of detail or explanation necessary to make a communication clear, accurate, and understandable will depend, in part, on the breadth and sophistication of the intended audience. ... The lack of financial sophistication of the recipient will often warrant a more detailed presentation."  [Translation:  Don't let the unsophisticated public hear you, lest their minds be blown by your brilliance.]

    3. Goldman Rule:  "Of course, your communications should never contain obscene, offensive, or otherwise inappropriate, unprofessional, or unlawful language. Remember, that you do not control and you cannot always predict who the reader will be."  [Translation:  Don't let the unsophisticated public hear you refer to them as, the unsophisticated public. (Whoops!)]

    4. Goldman Rule:  "Casual correspondence, thank you notes, confirmations or schedules for meetings, invitations, and other correspondence that does not relate to business does not require approval."  [Translation If you have to ask if it's going to waste our time, don't do it - e.g., casual correspondence.]

    5. Goldman Rule:   "It is the policy of the firm to make no comment on rumors whatsoever, even to deny rumors you believe to be untrue."  [Translation  Don't talk to your friends about Goldman Sachs, or you could be fired.]

    6. Goldman Rule:  "Prior to recommending that a customer purchase, sell or exchange any security, salespeople must have reasonable grounds for believing that the recommendation is suitable."  [Translation  Don't get us sued, or charged with fraud.]

    7. Goldman Rule:   "All sales correspondence from or to employees working from home offices must be routed through regional offices for purposes of review, approval, distribution and retention."  [Translation  Don't ever work at home. (Ideally, don't ever go home)]

    8. Goldman Rule:  "Each individual's correspondence must be sampled no less often than annually."  [Translation:  Don't try to tell us you didn't know you would be fired for disobeying.]

    9. Goldman Rule:  "'To All' memos ... must be approved as described in the section entitled 'Firmwide Memoranda' in the Employee Handbook."   [Translation:   Don't ever send a "To All" email.]

    10. Goldman Rule:  "Avoid superlatives and exaggerations." "Write using standard, formal written language." "Communicate succinctly. Stay strictly to the topic of your communication. Do not include any gratuitous comments."   [TranslationDon't waste any of your and/or the firm's time (the two are interchangeable) with needless words.]

    11. Goldman Rule:  "Firm employees frequently provide so-called 'trade ideas' to multiple recipients. Such trade ideas are designed to help clients take advantage of market conditions and intelligence, but are not intended to be specific buy/sell recommendations."  [Translation  Don't specify whether a "trade idea" is a "good idea" or a "bad idea."]

    12. Goldman Rule:   "Correspondence [directed to registered representatives involved in the sale of securities] will be opened by, or in the presence of, an authorized individual to identify any possible complaints."  [TranslationDon't do anything unless the lawyer ensures its legal.]

For further details, go to:   [Bloomberg/BusinessWeek,4/25/11]   and  [Clusterstock, 4/23/11]