Due to the current, absurdly low stock price, HHSE managers reached out this morning to a securities attorney to seek an opinion as to whether it was LEGAL and APPROPRIATE for Parkinson and / or Shefte to PURCHASE HHSE shares off the open market in order to achieve a substantial R.O.I. benefit for their trusts.
Here's a summary of the securities attorney's opinion:
1). Yes, public company officers are allowed to buy shares on the open market, but these shares immediately become "restricted" from regular resale, as with all other officer owned or controlled Rule 144 shares.
2). Yes, but if a public company officer buys any shares, these acquisitions or dispositions must be disclosed in a Form 4 filing with the S.E.C. "...before the end of the second business day following the day on which a transaction resulting in a change in beneficial ownership has been executed."
3). Yes, public company officers can profit from buying shares during artificially manipulated pricing dips, but not if the officers have any involvement with the traders or brokers that have created the artificially low pricing.
4). Yes, public company officers CAN act on their superior knowledge of a company's operations and activities and make wise investment decisions... PROVIDED... that all of the key elements for motivating an officer's direct purchase of shares are based on publicly disclosed information... in order that no non-affiliate shareholders are impeded from having the same, superior and accurate information about the company.
