Portfolio 15-4th: Inside Information: Prevention of Abuse

Wks. 1 Section 10(b) of the Securities Exchange Act of 1934 (15 U.S.C. §78j(b))

Wks. 2 Rule 10b-5 (17 C.F.R. §240.10b-5)

Wks. 3 Insider Trading and Securities Fraud Enforcement Act of 1988 (Pub. L. No. 100-704)

Wks. 4 Legislative History of the Insider Trading and Securities Fraud Enforcement Act of 1988 (House Report 100-910)

Wks. 5 Letter of the Securities and Exchange Commission Proposing New Insider Trading Legislation

Wks. 6 Sarbanes-Oxley Act of 2002 (Pub. L. No. 107-204), Section 409, Real Time Issuer Disclosures

Wks. 7 Section 16 of the Securities Exchange Act of 1934 (15 U.S.C. §78p)

Wks. 8 Regulations Under Section 16 (17 C.F.R. §240.16)

Wks. 9 Form 3: Initial Statement of Beneficial Ownership of Securities

Wks. 10 Form 4: Statement of Changes of Beneficial Ownership of Securities

Wks. 11 Form 5: Annual Statement of Beneficial Ownership of Securities

Wks. 12 Exchange Act Release No. 17,120, Tender Offers (Sept. 4, 1980)

Wks. 13 Rule 14e-3, Transactions in Securities on the Basis of Material, Nonpublic Information in the Context of Tender Offers

Wks. 14 Exchange Act Release No. 43,154, Selective Disclosure and Insider Trading (Aug. 15, 2000)

Wks. 15 Regulation FD

Wks. 16 Division of Corporation Finance: Manual of Publicly Available Telephone Interpretations, Fourth Supplement (June 8, 2001)

Wks. 17 Exchange Act Release No. 57,446, Report of Investigation Pursuant to Section 21(a) of the Securities Exchange Act of 1934: The Retirement Systems of Alabama (Mar. 6, 2008)

Wks. 18 Exchange Act Release No. 58,288, Commission Guidance on the Use of Company Web Sites (Aug. 1, 2008)

Wks. 19 New York Stock Exchange Listed Company Manual Section 2: Disclosure and Reporting Material Information

Wks. 20 NYSE Amex Company Guide: Part 4: Disclosure Policies (§§401–404)

Wks. 21 Excerpts From NASDAQ Marketplace Rules, Section 5000: NASDAQ Listing Rules*

Wks. 22 Sample Insider Trading Policy

Wks. 23 “Corporate Compliance Programs to Prevent Insider Trading Should Be Reevaluated in Light of Recent Developments,” Corporate Counsel Weekly (Apr. 24, 2002)

Wks. 24 Memorandum to Directors and Officers Regarding Section 16

Wks. 25 Vincent F. Chiarella v. United States, 445 U.S. 222 (1980)

Wks. 26 Raymond L. Dirks v. Securities and Exchange Commission, 463 U.S. 646 (1983)

Wks. 27 Basic, Inc. v. Levinson, 485 U.S. 224 (1988)

Wks. 28 United States v. O’Hagan, 521 U.S. 642 (1997)

Wks. 29 Staff Accounting Bulletin No. 99, 64 Fed. Reg. 45,150 (Aug. 19, 1999)

Wks. 30 U.S. Securities and Exchange Commission Definition of Insider Trading

Wks. 31 Speech by SEC Staff: “Opening Remarks to the Securities Industry and Financial Markets Association Regulatory Symposium on Insider Trading”

Wks. 32 Speech by SEC Staff: “Insider Trading – A U.S. Perspective” (Sept. 19, 1998)