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Tag Archives: insider trading

Second Circuit Maintains Expansive View of Civil Liability for Insider Trading

Posted in Enforcement, Insider Trading, SEC Enforcement

On February 18, 2014, in SEC v. Contorinis,[1] the Court of Appeals for the Second Circuit affirmed an order requiring Joseph Contorinis to personally disgorge more than $7 million in insider trading profits realized by a fund he co-managed, even though he did not personally receive those profits. In doing so, the court continued its… Read More

New FINRA Supervision Rules Impact Broker-Dealers’ Insider Trading Procedures and Supervisory Controls

Posted in Broker-Dealer Regulation, Enforcement, FINRA Enforcement, Insider Trading, SEC Enforcement

Financial Industry Regulatory Authority (FINRA) rules require member firms to establish and maintain a system of written procedures to supervise the activities of its members. On December 23, 2013, the SEC approved new FINRA rules. Among other provisions, the new rules require procedures for detecting and reporting insider trading and impose heightened standards on supervisory… Read More

Is Exercising Employee Stock Options Illegal Insider Trading? Maybe

Posted in Broker-Dealer Regulation, Enforcement, Insider Trading, SEC Enforcement

Amidst the flurry of Securities and Exchange Commission (SEC) cases involving improper employee stock option backdating several years ago, many commentators opined on the potential insider trading implications of companies’ issuance of stock options to officers and directors. Yet the literature is surprisingly scant concerning the potential insider trading implications of an insider exercising her… Read More

Inside Baseball

Posted in Enforcement, SEC Enforcement

Baseball fans and legal practitioners alike gathered on June 17 to hear co-director George Canellos of the SEC Enforcement Division lay out some ambitious plans for the agency. Asked about the SEC’s new lineup, Canellos gave fellow co-director Andrew Ceresney and newly appointed Chair Mary Jo White his vote of confidence, noting that they were… Read More

The SEC Speaks: Reflections and Enforcement Initiatives in 2013

Posted in Enforcement

When the SEC talks, people listen. And securities enforcement professions look forward all year to listening to the Commissioners and the SEC’s senior leadership speak at The SEC Speaks conference. In particular, discussions about the Division of Enforcement’s trends and priorities ranks as one of the most anticipated panels at the conference. This year, uncertainty about the… Read More