8e. ALL LAB – “Reasonable” Procedures to Prevent Misuse of MNPI (Intermediate)

Deficiency letters and enforcement proceedings frequently address alleged weaknesses in procedures directed toward controlling misuse of material non-public information.  This session will discuss possible lessons and open questions relating to MNPI procedures, including the vexing question of when such procedures are “reasonably designed.”  This session is closed to both regulators and members of the press.

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