Firm Memoranda

SEC v. Office Depot: SEC Aggressively Enforces Regulation FD

Date: 10/27/10

The recent sanctions of the Chief Executive Officer ("CEO") and former Chief Financial Officer ("CFO") of Office Depot, Inc. (the "Company") for their roles in orchestrating and coordinating an effort by which other executives of the Company communicated material nonpublic information to selected securities analysts and institutional investors serves as a forceful reminder that the Securities Exchange Commission ("SEC") intends to vigorously enforce the requirements of Regulation FD., Regulation FD prohibits issuers or persons acting on their behalf from disclosing material nonpublic information to securities analysts, institutional investors, or other enumerated persons without disclosing that information to the public.

CGR Memo - SEC v Office Depot - SEC Aggressively Enforces Regulation FD.pdf (pdf | 39.23 KB )