(1) Analysts, institutional investors, investment dealers and other market professionals who receive material undisclosed information from a company are “tippees”. It is against the law for a tippee to trade or further inform anyone about such information, other than in the necessary course of business.
(2) We recommend that analysts, institutional investors and other market professionals adopt internal review procedures to help them identify situations where they may have received nonpublic material information and set up guidelines for dealing with such situations.