[Congressional Record Volume 161, Number 41 (Wednesday, March 11, 2015)]
[Senate]
[Pages S1440-S1441]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
By Mr. REED (for himself and Mr. Menendez):
S. 702. A bill to strengthen the prohibitions on insider trading, and
for other purposes; to the Committee on Banking, Housing, and Urban
Affairs.
Mr. REED. Mr. President, I am joined by Senator Menendez in
introducing the Stop Illegal Insider Trading Act to finally define the
offense of insider trading. The need for this legislation is long
overdue because, in the absence of a statutory definition, an
inconsistent and complicated body of common law has developed as the
courts have used varying interpretations of anti-fraud statutes in
order to decide insider trading cases.
For illustrative purposes, consider the following example. A
financial analyst receives information from an insider at XYZ
Corporation, which contains XYZ's earnings before this information is
publicly released. This analyst then shares this inside information
with his portfolio manager who subsequently trades in XYZ stock.
Based on this hypothetical, I suspect most Americans would be
skeptical about someone who learned of a company's earnings before this
information was publicly released and then subsequently traded on such
information. Indeed, I believe most would agree that such a person was
given an unfair advantage in our securities markets.
However, on December 10, 2014, the United States Court of Appeals for
the Second Circuit in United States v. Newman decided that the
portfolio managers in this case were not guilty of insider trading
because as the New York Times summarized it, ``prosecutors had to show
that both men knew that the original source of the inside information
had breached a fiduciary duty and had received a personal benefit in
return.''
This decision defies common sense. It should not matter whether
someone, who traded on material information that was not publicly
available, knew whether the source of such information breached a
fiduciary duty and additionally received a personal benefit in return
for sharing this inside information. Such a decision is one of many
that has caused too many of our citizens to lose faith in government
and our courts. Indeed, some prosecutors have noted that the Second
Circuit's decision in Newman ``might make it difficult to file charges
against a parent who passes on a confidential stock tip to one of his
children without receiving anything in return.'' This is plainly not
right and contributes to a larger sense of injustice.
The greater irony, however, is that those who deal with insider
trading law the most agree that something must be done to restore
reason.
For example, Duke Law School Professor James D. Cox noted that ``all
studies of significant corporate events document that a significant
portion of the market movement associated with corporate events occurs
before the event is announced; for example, forty to fifty percent of
the price gain associated with a merger or takeover occurs before the
transaction's announcement . . . One can thus surmise not only that
corporate insiders are not very good about keeping secrets, but that
their tippees are delighted that they do not. That is, remote tippees
are likely both pervasive and truly are insidious. Newman pours gas
onto this raging fire.''
Most ironically, Judge Barrington Parker of the Second Circuit Court
of Appeals who delivered the Newman opinion remarked during oral
arguments, ``I'm concerned the government's position on key points of
the law seems to vary based depending on which judge you're talking
to.''
Moreover, University of North Carolina Law School Professor Thomas
Lee Hazen recently stated, ``no matter how narrow or broad people
believe the definition of insider trading should be, virtually everyone
is now in agreement that we'd be a lot better off if Congress would
simply bite the bullet and define it . . . the situation is a mess.
That's how you end up with cases like Newman.''
This is precisely what Senator Menendez and I are doing in
introducing this legislation today. We are seeking to finally define
the offense of insider trading with a clear and simple bright line
rule. Simply put, if a person trades a security on the basis of
material information that the person knows or has reason to know is not
publicly available, then they have engaged in unlawful insider trading.
Under our legislation, it is irrelevant whether the trader knew of
the source's fiduciary duty or whether the source derived any personal
benefit. What matters is whether the trader knew or has reason to know
that such trader had an unfair advantage in being given material
information that was not shared with the broader public. In addition,
we have taken care to ensure that those who take the time to
independently develop their own information from publicly available
sources can trade on this independently developed information so that
publicly available information can be analyzed and interpreted without
fear of liability. Lastly, because there may be situations that do not
necessarily rise to the level of unlawful insider trading, we have
provided the Securities and Exchange Commission with the flexibility to
provide exemptions from insider trading liability as long as such
exemptions are necessary or appropriate in the public interest and
consistent with the protection of investors.
In short, by making it an offense for those who contribute to a
securities market rigged in favor of the well connected, our
legislation focuses on providing everyday investors with a fair shot at
seeing some returns after investing their hard-earned savings.
Incidents of insider trading, and the perceived pervasiveness of the
practice, have for years served to validate the public's worst
assumptions about Wall Street culture. It is time we clearly define
what is appropriate under the law and take this meaningful step towards
improving the integrity of our securities markets for professional
traders and amateur investors alike.
[[Page S1441]]
I would like to thank Senator Menendez for working with me on this
legislation. I also thank Public Citizen, Americans for Financial
Reform, and the Consumer Federation of America for their support, and I
urge our colleagues to join us in supporting the Stop Illegal Insider
Trading Act.
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