Client Alert - SEC Enforcement Action Targets Implied Signals to Analysts - R. Bivans, co-author

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On October 21, 2010, the SEC announced an enforcement action against Office Depot and its CEO and CFO for alleged violations of Regulation FD in connection with Office Depot representatives’ selective signals to analysts to lower their quarterly earnings estimates by pointing out in one-on-one telephone conversations the recent public earnings announcements by comparable companies and reminding analysts of Office Depot’s prior statements about expected earnings. The enforcement action reemphasizes the SEC’s view that implied signals may violate Regulation FD even though only publicly-available information was discussed during a private conversation. This Client Alert summarizes the enforcement action, provides insight into the background of Regulation FD and sets forth pragmatic steps a public company may wish to take.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Roger Bivans | Attorney Advertising

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