HUMBL Inc (HMBL)

[surfkast]

It appears that if he discloses non public information to a select few it is a violation. Also there could be an issue with the SEC



§ 243.100 General rule regarding selective disclosure.


https://www.law.cornell.edu/cfr/text/17/243.100


What Must Companies Do To Ensure Compliance?

As the SEC has cautioned, material, nonpublic information disclosed on social media can be deemed selective disclosure and each case requires a rigorous Regulation FD analysis. Per SEC guidelines, the following is a non-exhaustive list of factors that companies and corporate executives must take into consideration in order to ensure compliance with Regulation FD. First, before using social media to disclose material, nonpublic information, companies must make investors aware of which social media account(s) they plan to use. The SEC recommends that companies alert investors in advance through their websites, in press releases, or, like Tesla, in a Form 8-K.15 Second, access to the particular social media account must not be restricted; the general public must have access to it.16 While the SEC has not opined on “blocking,” it stands to reason that specific individuals cannot be blocked from viewing the account. Third, investors must be able to efficiently find information about the company. Material, nonpublic information should be prominently disclosed and presented in a format readily accessible to the general public.17 Fourth, investors must be afforded a reasonable waiting period to react to such information. That is, companies need to wait a reasonable period of time for the information to disseminate before considering it publicly disclosed. Companies should look at the particular facts and circumstances in determining what may be a reasonable waiting period (e.g., the size and market following of the company, the nature and complexity of the information, and the extent to which the account is regularly accessed).18 And fifth, companies and their corporate executives must endeavor to ensure that statements on social media are not false or misleading.


https://www.lexology.com/library/detail.aspx?g=e41ffb08-80b5-4b43-8d0f-50911c7b7b6e


I do not pass judgement on the above facts taken from Cornel or Lexus.

I believe any questions should be referred the General Counsel.


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