Jonsie: I just did a quick review of the SEC interpretive guidelines issued in August of last year. The guidelines generally talk about how a company could satisfy Reg FD requirements by publicy releasing info on the company website.
And footnote 60 of the guidelines reads as follows:
"For purposes of Regulation FD, a posting on a blog, by or on behalf of the company, would be treated the same as any other posting on a company's web site. The company would have to consider the factors outlined above to determine if the blog posting could be considered 'public.' "
To understand the "factors outlined above" that must be considered, one would have to read the guidleines.
Therefore, based on my quick review of the above, the use of Bena's blog by the company to issue a PR would seem - unless other factors are present - to satisfy Reg FD requirements, even if the PR does not appear on the company's own website. Still, I think it would be good practice to simultaneously have the PR appear in both places. Of course, Bena would be well-advised to publish such a PR immediately upon receipt so as to avoid any potential issues that might arise if she waited.
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