Robert A. Cohen, Michael Kaplan, John B. Meade, Joseph A. Hall and Martine M. Beamon

Davis Polk Discusses SEC’s Expansive View of Accounting Control Violations

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After receiving board approval to buy back stock under a 10b5-1 plan, a company interpreted Rule 10b5-1 in a manner with which the SEC disagreed. The SEC did not allege that the company traded on the basis of material nonpublic …