When Steak and a Massage Equals Insider Trading — SEC Actions

Is “wine, steak, and visits to a massage parlor” a quid pro quo personal benefit which, if received in conjunction the dissemination of material, non-public information, is sufficient to establish a breach of duty for illegal tipping in violation of the federal securities laws? The first circuit court of appeals recently concluded that it is sufficient in that circuit, conceding that it may not be in others. U.S. v. Parigian, No. 15-1994 (1st Cir. Decided May 26, 2016).

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