Mayer Brown analyzed 34 insider trading policies to understand how large financial institutions address the heightened insider trading risks they face relative to other public companies. We analyzed the insider trading policies of 24 publicly traded investment banks, nine publicly traded private equity sponsors and one publicly traded financial institution with substantial operations in both investment banking and private equity management (which institution we include in both the investment bank and private equity sponsor statistics herein). Since the nature of their business necessarily creates both frequent opportunity for insider trading (especially in other companies’ securities, including through “shadow trading”) and a large universe of employees with access to material non-public information, a survey of how these types of large financial institutions generally address such risks in their insider trading policies can be informative to financial institutions reviewing their existing policies.
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