In a March 21 speech made at the IA Watch Annual IA Compliance Best Practices Seminar, Carlo V. di Florio, director of the SEC Office of Compliance Inspections and Examinations, emphasized that contrary to some reports, the investigations and cases relating to expert networks:
“[D]o not represent some inherent hostility by the Commission toward expert networks, nor do they indicate that the Commission is seeking to undermine the mosaic theory, under which analysts and investors are free to develop market insights through assembly of information from different public and private sources, so long as that information is not material nonpublic information obtained in breach of or by virtue of a duty or relationship of trust and confidence.”
Expert Networks: New Commentary by SEC Officials About Insider Trading, Schulte Roth & Zabel
