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Re: gitreal post# 3719

Tuesday, 12/06/2016 9:11:46 PM

Tuesday, December 06, 2016 9:11:46 PM

Post# of 3947

Any thoughts on what social media is acceptable for company disclosure - I know that Facebook and Twitter seem to be allowed. But where do you draw the line? Doesn't the company have to designate a particular forum as its official disclosure site?



Here is the official SEC release on the matter:

https://www.sec.gov/News/PressRelease/Detail/PressRelease/1365171513574

A company chat board is NOT "social media" and it would absolutely NOT be acceptable, as it is not available to everyone at the same time, and would definitely violate Regulation FD. As the release states:

"Regulation FD requires companies to distribute material information in a manner reasonably designed to get that information out to the general public broadly and non-exclusively. It is intended to ensure that all investors have the ability to gain access to material information at the same time."

Having to register and sign in to see the information would not qualify as "non-exclusively". It also would not give information to everyone at the same time as, say, Twitter would, as it will feed the information to people rather than people having to go there to see it.

No doubt that IS selective disclosure and a violation of Regulation FD. The method also has to announced publicly ahead of time so people know where to look for the info. Which also makes such disclosure ANOTHER violation.

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