Co-Directors of Enforcement Stephanie Avakian and Steven Peikin cautioned companies of the heightened risk of insider trading based on coronavirus-related circumstances that for many companies likely include directors, officers, and a more extensive group of employees and consultants/advisors (relative to the ordinary course) being regularly exposed to considerable material inside information about the company. The Co-Directors reminded companies to be mindful of the importance of adhering to corporate controls and procedures including insider trading policies, DC&P, Reg. FD, and codes of ethics/conduct.
See CNBC's "SEC warns on coronavirus insider trading after stock sales by NYSE chair, his wife Sen. Loeffler, 3 other senators"; last week's coronavirus-related report: "Review Insider Trading Process & Policy"; our report here: "Executive Health Disclosure Considerations"; and additional information & resources on our Insider Trading/Section 16, Regulation FD, Financial Reporting, Compliance & Ethics, and SEC Enforcement pages.
Watch your inbox for an invitation to register for a near-term Society webinar on this topic.
This post first appeared in the weekly Society Alert!