16Nov
When Do M+A Discussions Constitute MNPI? Recent SEC Guidance May Shed Some Light
Last month, the SEC announced that a public company had agreed to pay a $20 million penalty to resolve charges related to its repurchase of stock while supposedly in possession of material, non-public information (“MNPI”) that it might be acquired by another company. The SEC’s cease and desist order offers important lessons for assessing whether a company is in possession of MNPI in the context of ongoing M&A discussions....
By:
Goodwin
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