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发表于 2011-7-11 15:27
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Ethics Question: Mosaic Theory
Hey guys, I've come across a question that has me puzzled. Please take a look.
Question:
Jeremy LeCroy is a compliance officer with Overton Securities. He is in a bar when he overhears an acquaintance that he knows is in the IT Department of a local software company complaining about problems with the comany's new database management program. Because LeCroy is a shareholder of the company, this concerns him. He goes on the internet to do additional research and finds that the problem has been widely commented upon by bloggers. As a result, LeCroy sells his stock the next morning. Is this a violation of the standards
a) No. Because LeCroy learned about the info in a bar (which is a public place), the information is by definition in the public domian
b) No. Although LeCroy first heard about the information from a material, non public source, he verified it from sources in the public domain.
c) Yes. LeCroy overheard a private conversation -- by definition this is material, non-public information.
The correct answer is "B".
My rationelle is this:
"A" is wrong because it doesn't matter where you hear what you hear, or see what you see, that classifies it as public or private information.
"B" is iffy in my eyes because it says clearly he is in posession of material, non public information, which you are forbidden to act on, or cause others to act on.
The mosaic theory lets you use public information and non-material, non public information to reach a conclusion. So if the information he got in the bar is from a material non-public and the material he got off the blogs to confirm everything is public... then by definition what he heard in the first place wasn`t material non-public information, it was just public information.
"C" is wrong because the information is not material non-public just because its overheard in a private setting.
Is this tricky, or am I looking to far into this? |
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