Material information

Garvey work as waitress in a restaurant. She hears two employees of a major brokerage house discussing Metrona, a nanotechnology company. The two employees says that they will issue a report with buy rating on Metrona in two days. Next morning, Garvey buys 40 shares of Metrona for her own account.

Is Garvey violate Standard IIA Material Nonpublic Information?

yes

Why?

And what if Garvey buys only 1 share?

doesn’t matter how many shares, as long as he acts on it or cause others to act on it, it’s a violation.

Ah yes, I thought that trading 40 shares is not material, but the criteria “Material” is based on the information and not on the action on the trading.

Thanks.