Jeffrey Thomas

About Jeffrey Thomas

JEFFREY R. THOMAS represents clients in securities matters, corporate and business matters, employment matters, and civil litigation.

SEC Issues Guidance on Companies’ Use of Social Media to Make Corporate Disclosures

The SEC recently issued a so-called “21(a) report” concerning the application of Reg FD to corporate disclosures made through social media.  The report arose out of a SEC investigation into whether Netflix CEO Reed Hastings violated Reg FD by using his personal Facebook page to announce Netflix streaming metrics.

Reg FD prohibits public companies, or persons acting on their behalf, from selectively disclosing material, nonpublic information to certain securities professionals, or shareholders where it is reasonably foreseeable that they will trade on that information, before it is made available to the general public.  Reg FD requires that companies and those acting on their behalf distribute the information in a manner reasonably designed to achieve effective, broad and non-exclusionary distribution to the public.

In its report, the SEC made the following two main points:  First, companies must examine communications through social media for compliance with Reg FD.  Second, the principles outlined in the SEC’s 2008 Reg FD guidance concerning the use of websites to disseminate corporation information apply with equal force to corporate disclosures made through social media channels.  Most notably, companies must ensure that the social media channel is a “recognized channel of distribution” by alerting the market to the fact that the company will use the social media channel to disseminate corporate information.

U.S. Supreme Court: “Discovery Rule” Does Not Apply to Five-Year Limitations Period for SEC Penalty Claims

The limitations period for penalty claims in SEC enforcement actions is governed by 28 U.S.C. Section 2462, which states that “an action … for the enforcement of any civil fine, penalty, or forfeiture” must be brought “within five years from when the claim first accrued.”  In Gabelli v. SEC, the Supreme Court rejected the SEC’s argument that the “discovery rule” applies to SEC penalty claims.  That rule, which is an exception to the standard rule that a claim accrues when the plaintiff has “a complete and present cause of ac­tion,” delays accrual until a plaintiff has “discovered” his cause of action.  The Court distinguished lawsuits by fraud victims, in which the discovery rule has been applied, from government enforcement actions.  Unlike fraud victims, who may have no reason to suspect fraud, the SEC’s very purpose is to root out fraud, and it has many legal tools at hand to aid in that pursuit.  Also, the gov­ernment in enforcement cases seeks a different type of relief than fraud victims:  A fraud victim seeks compensation for his injuries, whereas the government seeks civil penalties, which go beyond compensation and are intended to punish and label defendants wrongdoers.