Could a trade based on intuition and observing a chance encounter between a business contact and an executive of a publicly listed company at a charity event result in insider trading charges? The Securities and Exchange Commission’s recent enforcement action against Richard Bruce Moore suggests that the answer to that question is yes. The SEC’s complaint against Moore, a former investment banker with Canadian Imperial Bank of Commerce (“CIBC”) in Toronto, underscores the SEC’s expansive views on materiality and the existence of a fiduciary or fiduciary-like duty in insider trading cases….
‘Enforcement 40’ for 2020
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