Let’s say I know a few different asset managers from a 1 trillion dollar firm and they happen to say on Facebook that they are at XYZ internet company headquarters. I can tell that this their firm does not currently have an investment in this this company from the filings.
Defintiely doesn’t count as a reasonable basis. I get that. But what about material non-public info?
If they mention this on Facebook, that is no longer non-public.
Perfect, putting in my buy order now.
what if they only let ‘friends’ see their posts/activity, then it really isn’t public b/c there is no way an average Joe can see where they are or what they are doing
Is it against the code to front run your “friends” so long as they aren’t your client or employer?
It’s nonmaterial nonpublic info. Being “at” a place, or being “seen” in a place doesn’t qualify as material.
^ agree, perhaps they were just enjoying a slice of Sbarro in the food court? Because, who can resist Sbarro?
nonmaterial. just because they are there means squat.
nonmaterial nonpublic.
Nonmaterial nonpublic. It’ll be funny if they are there to announce bad news and you get hammered for violating the universe’s rule of reasonable basis.
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It’s definitely non-material. Also, the fact that the company isn’t listed in that investment manager’s filings doesn’t necessarily mean much. They could be short the stock (not likely for large institutional money managers but some of them do have long/short equity books as well), or they could have a trading position in it and as long as it isn’t in their book at the end of the calendar quarter, you won’t see it in the 13-F anyway.
Yeah, they are long only (100 percent certain).
They do not do trading positions. They are the kind of company that buys 15 percent of the company and sticks it into one of their mutual funds.
The one way you can ensure its public info is sharing with AF 
ha ha, good luck with your trade!