Question

Difficulty: EasyInsider Trading and Misuse of Material Nonpublic Information

An IT administrator at a publicly traded company accesses unreleased positive quarterly earnings data on a secure internal server and discloses the numbers to a close friend. The friend then purchases company stock prior to the public announcement and sells at a significant profit once the news becomes public. Which of the following statements regarding tipper and tippee liability under federal insider trading laws are correct?

  1. The IT administrator (tipper) can be held liable for insider trading even if they did not personally execute trades or receive direct financial compensation.Answer
  2. The friend (tippee) can be held liable for insider trading if they knew or should have known that the information was material, nonpublic, and disclosed in breach of a duty.Answer
  3. C
    The friend is exempt from insider trading liability because they are not an officer, director, or employee of the publicly traded company.
  4. D
    Insider trading violations apply exclusively to transactions executed directly in personal brokerage accounts registered under the insider's legal name.

Answer

The statements confirming that the IT administrator can be liable without trading or receiving direct compensation, and that the friend can be liable as a tippee if they knew or should have known the information was material nonpublic information obtained via a breach of duty, are correct.
Under the Insider Trading and Securities Fraud Enforcement Act and federal securities regulations, both tippers and tippees face liability. Tippers are liable for improperly sharing material nonpublic information regardless of whether they personally profit or trade. Tippees are liable if they trade while aware (or having reason to be aware) that the information was material, nonpublic, and provided in breach of a duty.

Step-by-Step Solution

1
Evaluate tipper liability requirements.
Confirm that an insider passing material nonpublic information breaches confidentiality duties and incurs liability regardless of whether they personally traded.
Passing corporate secrets to an outside party without a valid business purpose violates duty and constitutes illegal tipping.
2
Evaluate tippee liability requirements.
Confirm that trading on a tip creates liability if the tippee knew or should have known the information was confidential and improperly disclosed.
Tippees inherit the tipper's breach of duty when trading on material nonpublic information.
3
Identify incorrect statements.
Reject statements claiming non-employees are exempt or that rules only apply to personal account trades.
Federal insider trading laws extend full civil and criminal liability to tippees and indirect trading arrangements.

Key Concept

Elements of Tipper and Tippee Liability under Insider Trading Regulations
Estimated Time:1m 0s
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