Tag Archives: Alan Wilson

Cyber Experts React to Court Decision in the SEC’s SolarWinds Enforcement Action

Editor’s Note: PCCE has been watching the developments in the SEC’s enforcement action against SolarWinds and its CISO over allegedly misleading disclosures and controls failures related to the compromise of its Orion product by putative Russian hackers. In this post, cybersecurity experts and lawyers discuss the recent decision by U.S. District Judge Paul Engelmayer to dismiss most of the SEC’s claims in the case.

Photos of the authors

Top left to right: Randal Milch, Judy Titera, James Haldin, and Alan Wilson. Bottom left to right: Matthew Beville, Elizabeth Roper, and Jerome Tomas. (Photos courtesy of authors)

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SEC Adopts Amendments to Rule 10b5-1

by Alex Bahn, Erika Robinson, and Alan Wilson

Photos of the authors

From left to right: Alex Bahn, Erika Robinson, and Alan Wilson

In a surprising 5-0 vote, the SEC on December 14, 2022 adopted amendments to Rule 10b5-1, the SEC’s rule governing pre-arranged trading plans, as well as amendments to related disclosure and other rules.  The amendments impose significant restrictions on the adoption and use (from an affirmative defense perspective) of Rule 10b5-1 trading plans by directors, officers, and persons other than issuers.  The amendments also include several new disclosure and reporting requirements.

The SEC explained in the adopting release that the amendments are “designed to address concerns about abuse of the rule to trade securities opportunistically on the basis of material nonpublic information in ways that harm investors and undermine the integrity of the securities markets.” Continue reading →