ARTICLE
1 June 2020

SEC Issues Statement On Maintaining Market Integrity During The COVID-19 Pandemic

AO
A&O Shearman

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A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
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...
United States Corporate/Commercial Law

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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