Merrill analysts, meanwhile, were denigrating the companies in internal communications, Mr. Spitzer said.

"We came out pretty well," said one Merrill analyst.

Clearly, nothing in the new policies prevents a Merrill analyst from rating a stock a "buy" right up until he stops having an opinion.

One former Merrill analyst said the policy was painless for the firm.

"Let's face it," said the Merrill analyst.

In those messages, Merrill analysts appeared to be disparaging companies in private even as they were recommending their shares publicly.

The Merrill analysts recently published a study of cash drains at large technology companies.

He rocked the financial world with the findings he announced in April, including damaging e-mail messages among Merrill analysts.

Two weeks ago, he released internal notes from Merrill analysts that appeared to show that their private opinions conflicted with their rosier public views.

The Merrill analysts said they expected BNP's share price to dip initially and then recover over the medium term.