SEC Enforcment Issues Statement On Market Integrity

While the Securities and Exchange Commission ("SEC") is currently focused on maintaining orderly markets, and extending exemptions from reporting and delivery requirements for entities affected by the coronavirus (COVID-19), the agency is also closely following virus-related events with an eye toward maintaining market integrity. The Co-Directors of Enforcement at the SEC issued a statement March 23, 2020, outlining their main areas of concern.

First, they reminded issuers to continue to maintain and follow corporate controls and procedures, including disclosure controls and compliance with Regulation FD. Relatedly, the Co-Directors advised, in these uncertain times, of the greater potential for issuers to have more material non-public information, for dissemination of the information to be delayed, and for a larger number of people to be aware of this non-public information. These factors increase the risk that trading while in possession of this information could