Simpson Thacher Partners Author Article on the SEC Extending Its Focus on MNPI Clearance Procedures
11.12.20
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Partners Stephen Cutler, Nicholas Goldin, Brooke Cucinella, Michael Osnato and Josh Levine authored an article titled, “SEC Extends Its Focus on MNPI Clearance Procedures,” which was published by the Harvard Law School Forum on Corporate Governance. The article analyzed a recent SEC enforcement settlement of an action against a public company in connection with the company’s initiation of a stock buyback program while in possession of material, nonpublic information (“MNPI”). It further outlined a number of important matters for public companies to keep in mind. The article also noted that this case serves as a reminder that a public company—as regulated entities are expressly required to do—should take steps to ensure that its internal controls and processes for administering a stock buyback (as well as other securities transactions and public disclosures) are reasonably designed to ascertain whether the company may be in possession of MNPI.
To read the article, please click here.