ERHC Energy Inc (ERHE)

[TOB]

There is no such thing as "insider not acting" -Krombacher

Exactly, there is no such violation. Indeed, the whole point of the regulation is that those with insider information must not trade based upon that information, or selectively inform others of that information in a way that violated Reg FD. "Insider not acting" is exactly what the prohibition expects insiders to do. Lol.

There is, of course, also no prohibition from acquiring insider information. Surely senior ERHC management always has such information, and affiliates like Chrome are presumed to have special access, which is why they are listed as affiliates and their trading announced and scrutinized.

This is also why many financiers have in their variable funding contracts limits which prevent their passing the level at which they would be formally regarded as affiliates. They don't want the restriction to their trading, and are not privy to insider information outside of the context and restrictions of their agreements.