Sell side analysts can also have conflicting duties. One issue that has been brought up has been the idea of sell side stock rankings and maintaining a positive rating for an extended period of time. This was addressed in the New York Attorney General's case against Bank of America Merrill Lynch. It also has been proven that the longer an analyst has been following and researching a stock, the more and more favorable the recommendations become. The idea behind this is that the sell side analyst may become too comfortable and lose objectivity, something known as the capture hypothesis. Other conflicts of interest include opposing incentives for sell side analysts. Sell side analysts generally have a personal need for a good reputation, and if an analyst cares about their reputation he or she will try to report truthful information. However, analysts also have the desire to receive incentives to make positive recommendations because brokerage firms in and of themselves have internal conflicts of interest between differing departments such as trading, underwriting and sales. One conflict of interest would be the need for an analyst to provide this research mentioned above, i.e. research that is unbiased and reliable, which could lead to higher trading business for the firms for which the analysts work. Hence the trade-off or conflict of interest for an analyst would be the need for generating their firm business and their own personal career goals.