ERHC Energy Inc (ERHE)

[Krombacher]

No. *Anyone* may have access to insider information so long as they may not trade on the basis of that information. Such a restriction to not trade can be determined with a simple contract of confidentiality where the individual receiving such information does not trade on it. That is my interpretation, but see for yourself:

From the SEC website:

Regulation FD (Fair Disclosure) is a new issuer disclosure rule that addresses selective disclosure. The regulation provides that when an issuer, or person acting on its behalf, discloses material nonpublic information to certain enumerated persons (in general, securities market professionals and holders of the issuer's securities who may well trade on the basis of the information),

If agreements were signed with Offor whereby he may not trade on the basis of the information given, then Reg FD should not be deemed violated.

The full rules are here:

http://www.sec.gov/rules/final/33-7881.htm

Krombacher