Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at recent remarks by SEC Chairman Jay Clayton and Bill Hinman, director of the Division of Corporation Finance, on issues around insider trading compliance programs. Some of the issues we consider are:

  • Why would two high ranking SEC officials publicly address insider trading and compliance in the same week?
  • What are the rules around 10(b)5-1?
  • What about Albert Bourla, the CEO of Pfizer, who sold $5.6 million worth of Pfizer shares on Nov. 9, the day the company announced stellar results of its Covid vaccine trials.
  • Who owns insider trading compliance in a corporation?
  • Values based ethics v. rules based ethics.
  • Tom Moyer, former CCO and now head of Global Security at Apple indicted for alleged offering bribes to obtain concealed carry permits in Santa Clara County CA.

Resources

For more information see Matt’s blog posts:

SEC Warning on Insider Trading Sales

Apple Exec Indicted on Bribery Charge