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Current proposals include: (i) imposing a mandatory “cooling-off” period of 120 days for officers and directors, and 30 days generally, between when a plan is adopted or modified and when trading can commence; (ii) requiring directors and officers to personally certify to the company that they are not in possession of material nonpublic information at the time of adoption or modification of a plan; (iii) providing that the affirmative defense under Rule 10b5-1(c)(1) does not apply… [read post]
11 Apr 2022, 8:08 am by Dan Bressler
And it’s in the 2017 version of that resource from the even earlier version of that session (available here, with standard caveats that often updates, edits and removals are done for a reason) includes a specific story of law firm audit letters playing a role in a DOJ matter: SEC v. [read post]
3 Apr 2022, 9:30 pm by ernst
Hastie, later judge of the U.S, Court of Appeals for the Third Circuit; Spottswood Robinson III, later chief judge of the U.S. [read post]
1 Apr 2022, 6:14 am by John Floyd
  Schedule V   The substances on this schedule have a low potential for abuse and usually consist of substances that are preparations containing narcotics. [read post]