SEC Enforcement Action Against
Schering-Plough And Its Former CEO Under Regulation FD
The SEC has imposed the most severe sanctions to date in relation to Regulation FD violations. Earnings information and stock repurchase plans are subject matters that have been specifically highlighted as areas to be reviewed carefully by issuers prior to being selectively disclosed. This memorandum serves as a reminder that it is essential for senior management and investor relations personnel to be thoroughly briefed on the requirements so as to promote compliance with the Regulation.