When I was on the SEC’s enforcement staff, I had a case once where we were pretty sure our prospective defendant had engaged in insider trading. Our conversation with his lawyer went something like this...more
There has been renewed focus on Rule 10b5-1 Plans following an article in the Wall Street Journal, published on November 27, 2012, entitled “Executives’ Good Luck in Trading Own Stock,” which reported that executives who...more
The aggressive use (or misuse) of Rule 10b5-1 trading plans is likely to become a significant area of focus for regulatory enforcement and securities class action plaintiffs. The floodlights now aimed at such plans are the...more
Rule 10b5-1(c) under the Securities Exchange Act of 1934, as amended, is intended to provide a safe harbor from insider trading liability for corporate insiders who trade their company’s stock pursuant to certain...more
In October of 2000, the Securities and Exchange Commission adopted Rule 10b5-1, which among other things, created an “affirmative defense” for pre-planned trading provided that specified conditions were met. At the time, I...more
In This Issue: Overview Of Insider Trading Law; 2012 Enforcement activity; Galleon Update; Expert Network Cases; What Does Cooperation Buy You?; Global Trading, Global Enforcement; Legislative Reform; 10b5-1 Plans: Not...more
On December 28, 2012, the Council of Institutional Investors (CII) submitted a letter to the Securities and Exchange Commission (SEC) requesting that the SEC implement rulemaking to impose new requirements with respect to...more
On November 28 the Council of Institutional Investors (CII), an association of public, corporate and union pension funds and other employee benefit plans, submitted a letter to Securities and Exchange Commission Chairman...more
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