The Ethics Line: Public Information Only
On August 10, 2000, the Securities and Exchange Commission, or SEC, adopted Regulation FD, short for Fair Disclosure, and it took effect on October 23 of that year. The rule addressed a practice that had become routine: companies sharing important information privately with favored analysts and large investors before telling everyone else. Under Regulation FD, when a listed company, or someone acting on its behalf, discloses material non-public information to certain market professionals or to shareholders who might trade on it, the company must make that information public. If the disclosure was intentional, publication must be simultaneous. If it was unintentional, publication must be prompt, which the rule defines as no later than the later of twenty-four hours or the start of the next day's trading on the New York Stock Exchange.
Regulation FD governs what companies may do. It is not, by itself, the rule that governs what you may do with information. That job falls mainly to the general anti-fraud provisions of the Securities Exchange Act of 1934, and in particular to the SEC's Rule 10b-5, under which trading on material non-public information obtained in breach of a duty can be illegal. The details of insider trading law are a matter for lawyers, and nothing in this lesson is legal advice. But the practical line for anyone doing people-move intelligence is simple enough to state: work only with information that has been made public, and treat anything else as off limits.
Why spend a lesson on this in a course about executive movement? Because people moves sit unusually close to the line. An upcoming chief executive change, before it is announced, can be material. A conversation at a conference with someone who mentions that a colleague is about to leave, or that a new division is being staffed, can put you in possession of exactly the kind of information that has not been made public. The hallway is where industry knowledge circulates, and it is also where a careful practitioner needs to know when to stop listening.
The earlier modules of this course were built entirely on public records: Form 8-K filings, proxy statements, press releases, company websites and published conference agendas. That was deliberate. Every example, from the Equinix succession announced on March 12, 2024, to the Digital Realty change of chief executive officer, or CEO, on December 13, 2022, rests on documents the companies chose to publish. A practice confined to such sources has a useful property: anything you conclude from them, anyone else could have concluded too. Your advantage comes from diligence and judgment, not from access.
There are ethical lines beyond the legal ones. Professional profiles are public, but they are also personal. Collecting them in bulk, combining them with other data, or using them to draw conclusions about a named individual's health, family, finances or reasons for leaving goes well beyond what this practice needs and well beyond what most people expect when they post their career history. The object of study is the company's strategy, as expressed through the roles it fills. It is not the private life of the people who fill them.
A few habits make the line easy to hold. Record the source and date of every piece of evidence, so you can show it was public when you used it. Separate what a document says from what you infer from it, and label the inference as yours. Decline to speculate, in writing or in conversation, about why a named person moved. And if you ever find yourself holding something that has not been made public, the right response is to stop and ask a lawyer, not to ask whether anyone would find out.
Faraday's read is that the ethics of this field and its analytical quality point the same way. Information that is public is also information that can be verified, dated and corroborated, which are the properties this course has argued matter most. Rumor and private tips are not only riskier; they are usually worse evidence. A practitioner who works only from the public record gives up very little, and gains a body of work that can be shown to anyone.
That is the practice in full: watch the roles companies fill, anchor each move to a filing, date it carefully, read the conference circuit as a curated self-portrait, weigh everything against base rates, and keep to what has been published. It is patient, unglamorous work, and the Regulation FD principle that everyone deserves to see material information at the same time is a sound one to carry into all of it.