On March 23, 2020, two co-directors of the SEC's Division of Enforcement released a statement emphasizing the importance of maintaining market integrity and following corporate controls and procedures in light of COVID-19. The statement reminds corporate insiders that the material non-public information that comes to their attention may hold an even greater value now than it would under usual circumstances, particularly if earnings reports or required SEC disclosure filings are delayed due to COVID-19. They asserted that insiders should be mindful of their obligations to keep this information confidential and comply with the prohibitions on illegal securities trading.
The statement encouraged public companies to be mindful of their established disclosure controls and procedures, insider trading prohibitions, and codes of ethics, and to ensure that they protect against the improper dissemination and use of material non-public information. Similarly, broker-dealers and investment advisers were reminded to comply with policies and procedures designed to prevent misuse of material, nonpublic information.
Originally published 13 May, 2020
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