Does relying on “industry experts” constitute insider trading?
There is nothing inherently wrong with hiring a company that arranges conversations between analysts or hedge fund managers and those who offer legitimate expertise to assist investors in making investment decisions. The information provided by experts can be part of the “mosaic” of information gathered by analysts or investment managers to assist them in the process of investment decision making. This type of information can include economic or industry forecasts.
Even if a piece of non-public immaterial information takes on significance when combined with primary research or other non-public immaterial information, the information may still be considered immaterial. This concept is known at the mosaic theory.
—Michael McMillan, director, ethics and professional standards at CFA Institute, and Jon Stokes head, standards of practice, driving at the difference between expert networks and insider trading: via FT
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23 March 2011 at 2:13 pm
just misunderstood « Stilltitled
[…] Compliance Inspections and Examinations, U.S. Securities and Exchange Commission, remarking on the misplaced focus on expert networks during the unfolding of the various insider trading scandals: via speech […]
28 March 2011 at 11:32 am
expert networks, controls, and controls for insider trading « Stilltitled
[…] CFA Institute commented on the speech and shared a reserved sense of relief on di Florio’s […]
24 May 2011 at 11:54 am
failure of analysis « Stilltitled
[…] Pavia, Editor, Investment News, boldly misstating the circumstances and failing to recognize the fact that Raj was accused of insider trading based on information obtained through personal […]
27 May 2011 at 4:45 pm
rich vein of corruption « Stilltitled
[…] this, at least it will serve as a lesson to the importance of compliance policies, procedures, and systems when speaking with outside experts, and at most, it may provide the contours of a gripping movie. […]