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News December 7, 2015 Issue

Warning: Political Intelligence May Be Material Non-Public Information

Advisers receiving information from political intelligence firms – or advisers that themselves act as political intelligence firms – need to ensure that any intelligence received or forwarded does not constitute material non-public information, and that they have the proper policies and procedures in place if it does. Firms that fail to do so may find themselves in the SEC’s cross-hairs.

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