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16118724 SEC Complaint Against Former Country Wide CEO Angelo Mozilo 1

16118724 SEC Complaint Against Former Country Wide CEO Angelo Mozilo 1

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Published by: Peter on Jun 05, 2009
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10/18/2011

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in effect, dated as of June 24, 2005, which prohibited trading in Countrywide

securities on the basis of material non-public information. The policy included a

section entitled “Material Information” that stated:

3.2 Material Information

U.S. federal securities laws prohibit
transactions while aware of material
nonpublic information. “Material”
information means information relating to the

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company with publicly traded securities,
which, if publicly disseminated, would likely
affect the market price of any of its securities,
or which would likely be considered
important by a reasonable investor in
determining whether to buy, sell, or hold such
securities.

In addition, the policy included a section regarding 10b5-1 sales plans that stated:

4.3 10b5-1 Trading Arrangements

A. Section 10b5-1 of the Exchange Act creates
an exception to the prohibition against trading
while in the possession of material nonpublic
information. In order to take advantage of the
exception set forth in Section 10b5-1 of the
Exchange Act, Directors and Executives
Officers must enter into a 10b5-1 Trading
Plan; provided that such Trading Plan:

i.

specifies the amount of shares to be
purchased or sold and the price at
which and the date on which the shares
are to be purchased or sold; or

ii.

includes a written formula or
algorithm, or computer program, for
determining the amount of shares to be
purchased or sold and the price at
which and the date on which the shares
are to be purchased or sold; or

iii.

does not permit the individual to
exercise any subsequent influence over
how, when or whether to effect
purchases or sales; provided, in
addition, that any other person who,
pursuant to the contract, instruction, or
plan, did exercise such influence must
not be aware of the material nonpublic
information when doing so; and

iv.

was acknowledged by Countrywide in
writing and pre-cleared by the Office of
the Chief Legal Officer.

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