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	<title>Comments on: Loose lips, loose morals, and outdated disclosure practices</title>
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	<link>http://www.irwebreport.com/daily/2009/10/22/loose-lips-loose-morals-and-outdated-disclosure-practices/</link>
	<description>&#124; Investor Relations Web Best Practices, Trends and News</description>
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		<title>By: Roundup &#38; review: IR industry reaction to the Galleon scandal &#171; Alpha Found &#8211; Opinion &#38; Analysis</title>
		<link>http://www.irwebreport.com/daily/2009/10/22/loose-lips-loose-morals-and-outdated-disclosure-practices/#comment-1120</link>
		<dc:creator>Roundup &#38; review: IR industry reaction to the Galleon scandal &#171; Alpha Found &#8211; Opinion &#38; Analysis</dc:creator>
		<pubDate>Sat, 24 Oct 2009 00:23:03 +0000</pubDate>
		<guid isPermaLink="false">http://www.irwebreport.com/?p=1316#comment-1120</guid>
		<description>[...] Dominic Jones of IR Web Report had a view that echoes ours to some extent: This case is not about Reg. FD and corporate insiders inadvertently saying more than they should because they’re blabbermouths. [...]</description>
		<content:encoded><![CDATA[<p>[...] Dominic Jones of IR Web Report had a view that echoes ours to some extent: This case is not about Reg. FD and corporate insiders inadvertently saying more than they should because they’re blabbermouths. [...]</p>
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		<title>By: Luis Fernando Moran de Oliveira</title>
		<link>http://www.irwebreport.com/daily/2009/10/22/loose-lips-loose-morals-and-outdated-disclosure-practices/#comment-1113</link>
		<dc:creator>Luis Fernando Moran de Oliveira</dc:creator>
		<pubDate>Fri, 23 Oct 2009 00:00:22 +0000</pubDate>
		<guid isPermaLink="false">http://www.irwebreport.com/?p=1316#comment-1113</guid>
		<description>Agree with the first part, not with the second:

1.	There are less than enlightened people (on occasion or otherwise) that will eventually do dumb things. Those can benefit from a refresh on disclosure. But yes, there are bad people and they are going to do bad things, regardless. Little an IR can do in this case.

2.	Let’s put aside for a moment the fact that company officers continue to be humans and have to socialize, interact, talk, etc with other people to carry on their daily lives. Let’s suppose that private conversations with an analyst or investor could be considered an FD offence. We would still be left with the not trivial problem of defining an analyst or an investor. What about the client that holds some stock on the company? Could he speak with the CMO in private as a client or not ?  

The thing is, Dominic, that there are perfectly good and legitimate reasons for wanting to speak with management other than a desire to obtain material non public information. As an investor (during a previous incarnation, if you will), part of my investment decision was based on things like body language and how bright a company officer came across during a normal conversation. Touchy-feely stuff, to be sure, but still.</description>
		<content:encoded><![CDATA[<p>Agree with the first part, not with the second:</p>
<p>1.	There are less than enlightened people (on occasion or otherwise) that will eventually do dumb things. Those can benefit from a refresh on disclosure. But yes, there are bad people and they are going to do bad things, regardless. Little an IR can do in this case.</p>
<p>2.	Let’s put aside for a moment the fact that company officers continue to be humans and have to socialize, interact, talk, etc with other people to carry on their daily lives. Let’s suppose that private conversations with an analyst or investor could be considered an FD offence. We would still be left with the not trivial problem of defining an analyst or an investor. What about the client that holds some stock on the company? Could he speak with the CMO in private as a client or not ?  </p>
<p>The thing is, Dominic, that there are perfectly good and legitimate reasons for wanting to speak with management other than a desire to obtain material non public information. As an investor (during a previous incarnation, if you will), part of my investment decision was based on things like body language and how bright a company officer came across during a normal conversation. Touchy-feely stuff, to be sure, but still.</p>
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