When Regulation Fair Disclosure (FD) was adopted in August 2000, many public companies adopted policies addressing the permissible manner of communications with analysts and the investment community. Now, 12 years later, it is critically important for public companies to revisit their policies, or adopt a new policy if none exists.
Lessons from the SEC’s enforcement of Regulation FD
Key elements of an effective Regulation FD policy
A Regulation FD policy should address, in a comprehensive manner, the procedures for dealing with situations where a potential Regulation FD violation could occur. Key provisions of an effective Regulation FD policy include: