Todos os emissores regulados pela SEC passarão a divulgar periodicamente suas Políticas de Insider Trading, bem como negociações de suas ações realizadas por Insiders, seguindo nova exigência da entidade americana pela...more
On January 17, 2017, Judge Nicholas G. Garaufis of the United States District Court for the Eastern District of New York dismissed a putative class action asserting claims under Sections 10(b), 14(a), and 20(a) of the...more
The Second Circuit’s recent decision in Singh v. Cigna Corp., confirms that puffery regarding a corporation’s compliance program cannot form the basis for a stock drop suit. In 2012, Cigna sought to expand its Medicare...more
I am sometimes surprised by the number of insiders who trade in their company’s stock outside of Rule 10b5-1 trading plans. It is often said, with some accuracy, that executive officers, directors and other insiders always...more
For many public companies, the first issue they have to confront after they receive a government subpoena or Civil Investigative Demand (“CID”) is whether to disclose publicly that they are under investigation. Curiously, the...more