(1) You should consider using the following disclosure model when making a planned disclosure of material corporate information, such as a scheduled earnings release:
(a) issue a news release containing the information (for example, your quarterly financial results) through a widely circulated news or wire service;
(b) provide advance public notice by news release of the date and time of a conference call to discuss the information, the subject matter of the call and the means for accessing it;
(c) hold the conference call in an open manner, permitting investors and others to listen either by telephone or through Internet webcasting; and
(d) provide dial-in and/or web replay or make transcripts of the call available for a reasonable period of time after the analyst conference call. [FN 42]
(2) The combination of news release disclosure of the material information and an open and accessible conference call to subsequently discuss the information should help to ensure that the information is disseminated in a manner calculated to effectively reach the marketplace and minimize the risk of an inadvertent selective disclosure during the follow-up call.
FN 42 This model disclosure policy was recommended by the SEC in the adopting release to Regulation FD.