[stanfordkid]

I agree that a citation is needed ;)

But in this case I think the case history points to OP being right, though you'd likely have to have a pretty egregious and clear pattern of such activity, and it would have to be deemed material information:

https://www.reuters.com/article/us-sec-capitalone-insidertra...

[tptacek]

The Vitaly Korchevsky indictment probably comes close to demonstrating a model of what this would look like:

https://www.justice.gov/usao-nj/file/765216/download