Time to loosen up on corporate insider trading policies?
Some folksespecially those living in the states governed by the U.S. Court of Appeals 2nd Circuitmight believe that it's now okay to relax corporate insider trading policies. But don't do it.
March 31, 2015 at 08:00 PM
4 minute read
Some folks—especially those living in the states governed by the U.S. Court of Appeals 2nd Circuit—might believe that it's now okay to relax corporate insider trading policies. But don't do it.
Why would anyone even consider loosening up a corporation's insider trading policy? After all, the Securities and Exchange Commission (SEC) has had a string of conviction victories for insider trading tipper/tippee liability, including the high-profile conviction of former Goldman Sachs director Rajat Gupta.
The answer is the surprising victory the 2nd Circuit handed the defendants in United States v. Newman in 2014.
This decision came after a years-long court battle. Defendants Todd Newman, formerly of Diamondback Capital Management, and Anthony Chiasson, co-founder of Level Global Investors, were sentenced to jail time for allegedly trading on material, non-public information as tippees, in violation of federal securities laws.
These hedge fund portfolio managers traded on material non-public information that was given to them by their analysts. The information was originally shared amongst a group of analysts from different hedge fund firms via email.
You may be wondering why these analysts would trade tips with their competitors. According to one Bloomberg article, an ex-analyst for Diamondback Capital Management, Jesse Tortora, testified that it “allowed us to be more effective, more efficient and more profitable than working alone.”
So, were Newman and Chiasson guilty of violating the rules against insider trading under a theory of tippee liability?
To the surprise of many, the 2nd Circuit said no. The court held that for tippee liability to exist, the tipper must have gained substantial personal benefit from giving the tip, and the tippee must have knowledge about that substantial personal gain.
In Newman, the 2nd Circuit declared there wasn't sufficient evidence to show that the defendants had knowledge that the tippers gained personal benefit, nor was there a case to show that the tippers gained substantial personal benefit at all. The fact that the defendants were far removed from the original source of information no doubt helped the court reach this conclusion.
The government tried to show that there was a personal benefit afforded to the source of information in the form of friendship and career counseling. The court was not impressed by the government's reasoning, explaining that under this logic “practically anything would qualify” as a benefit. In addition, there was no proof the defendants believed that the original tippers had gained any personal benefit in exchange for the information they supplied.
Even so, this case should not be taken as encouragement to loosen up corporate insider trading policies.
First of all, the 2nd Circuit only represents a handful of states. Other states may decline to follow Newman. Second, the government is appealing the Newman decision, so it may not remain the law of even the 2nd Circuit. Third, the SEC filed an amicus brief in support of the plaintiff's appeal on the matter.
In February, the head of SEC's enforcement division, Andrew Ceresney, was quoted as saying that he wasn't too worried about the decision. In fact, according to one report, he said that the SEC could adapt to the ruling, and that the agency holds a lower burden of proof when it comes to these matters versus criminal prosecutors.
Finally, the “win” isn't getting an acquittal after years of expensive litigation. The real win is never having to defend your behavior in a court of law.
Conservative corporate insider trading policies and appropriate training can help your employees achieve this real win by not engaging in a transaction that may draw regulatory scrutiny.
This content has been archived. It is available through our partners, LexisNexis® and Bloomberg Law.
To view this content, please continue to their sites.
Not a Lexis Subscriber?
Subscribe Now
Not a Bloomberg Law Subscriber?
Subscribe Now
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
You Might Like
View AllInside Track: How 2 Big Financial Stories—an Antitrust Case and a Megamerger—Became Intertwined
AT&T General Counsel Joins ADM Board as Company Reels From Accounting Scandal
How Gen AI Is Changing Legal Work for In-House Counsel
Trump Likely to Keep Up Antitrust Enforcement, but Dial Back the Antagonism
5 minute readTrending Stories
- 1Infant Formula Judge Sanctions Kirkland's Jim Hurst: 'Overtly Crossed the Lines'
- 2Trump's Return to the White House: The Legal Industry Reacts
- 3Election 2024: Nationwide Judicial Races and Ballot Measures to Watch
- 4Climate Disputes, International Arbitration, and State Court Limitations for Global Issues
- 5Judicial Face-Off: Navigating the Ethical and Efficient Use of AI in Legal Practice [CLE Pending]
- 6How Much Does the Frequency of Retirement Withdrawals Matter?
Who Got The Work
Michael G. Bongiorno, Andrew Scott Dulberg and Elizabeth E. Driscoll from Wilmer Cutler Pickering Hale and Dorr have stepped in to represent Symbotic Inc., an A.I.-enabled technology platform that focuses on increasing supply chain efficiency, and other defendants in a pending shareholder derivative lawsuit. The case, filed Oct. 2 in Massachusetts District Court by the Brown Law Firm on behalf of Stephen Austen, accuses certain officers and directors of misleading investors in regard to Symbotic's potential for margin growth by failing to disclose that the company was not equipped to timely deploy its systems or manage expenses through project delays. The case, assigned to U.S. District Judge Nathaniel M. Gorton, is 1:24-cv-12522, Austen v. Cohen et al.
Who Got The Work
Edmund Polubinski and Marie Killmond of Davis Polk & Wardwell have entered appearances for data platform software development company MongoDB and other defendants in a pending shareholder derivative lawsuit. The action, filed Oct. 7 in New York Southern District Court by the Brown Law Firm, accuses the company's directors and/or officers of falsely expressing confidence in the company’s restructuring of its sales incentive plan and downplaying the severity of decreases in its upfront commitments. The case is 1:24-cv-07594, Roy v. Ittycheria et al.
Who Got The Work
Amy O. Bruchs and Kurt F. Ellison of Michael Best & Friedrich have entered appearances for Epic Systems Corp. in a pending employment discrimination lawsuit. The suit was filed Sept. 7 in Wisconsin Western District Court by Levine Eisberner LLC and Siri & Glimstad on behalf of a project manager who claims that he was wrongfully terminated after applying for a religious exemption to the defendant's COVID-19 vaccine mandate. The case, assigned to U.S. Magistrate Judge Anita Marie Boor, is 3:24-cv-00630, Secker, Nathan v. Epic Systems Corporation.
Who Got The Work
David X. Sullivan, Thomas J. Finn and Gregory A. Hall from McCarter & English have entered appearances for Sunrun Installation Services in a pending civil rights lawsuit. The complaint was filed Sept. 4 in Connecticut District Court by attorney Robert M. Berke on behalf of former employee George Edward Steins, who was arrested and charged with employing an unregistered home improvement salesperson. The complaint alleges that had Sunrun informed the Connecticut Department of Consumer Protection that the plaintiff's employment had ended in 2017 and that he no longer held Sunrun's home improvement contractor license, he would not have been hit with charges, which were dismissed in May 2024. The case, assigned to U.S. District Judge Jeffrey A. Meyer, is 3:24-cv-01423, Steins v. Sunrun, Inc. et al.
Who Got The Work
Greenberg Traurig shareholder Joshua L. Raskin has entered an appearance for boohoo.com UK Ltd. in a pending patent infringement lawsuit. The suit, filed Sept. 3 in Texas Eastern District Court by Rozier Hardt McDonough on behalf of Alto Dynamics, asserts five patents related to an online shopping platform. The case, assigned to U.S. District Judge Rodney Gilstrap, is 2:24-cv-00719, Alto Dynamics, LLC v. boohoo.com UK Limited.
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250