Six months ago, Tom Hayes, CFA, left his position as a portfolio manager and accepted a position as senior portfolio manager at a smaller boutique firm. One of Hayes’s first recommendations at his new job is Selldex. He had researched and recommended the stock six months ago while employed at his old firm, and he still believes it has great investment potential. He recreates his Selldex research using information from public sources and makes the recommendation. According to the CFA Institute Standards of Practice, Hayes’s actions: