Stock broker underwriters must protect clients, disclose conflicts, avoid misrepresentation and prevent market manipulation. Regulation 39 requires a stock broker acting as an underwriter to protect client interests, act ethically, avoid misrepresentation of services or underwriting commitments, safeguard issuer confidential information, disclose dealings in issuer securities, notify clients of registration, penal or material financial changes and transfer outstanding business per client instructions. It mandates mechanisms to identify, disclose and resolve conflicts of interest equitably and prohibits creation of false markets, price rigging and passing unpublished price sensitive information.