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Christopher Clark and William Wright

SEC Charges Corporate Controller and His Brother-In-Law with Insider Trading Ahead of Merger Announcement

Litigation Release No. 24982 / December 11, 2020

Securities and Exchange Commission v. Christopher Clark and William Wright, No. 1:20-cv-01529 (E.D. Va. filed December 11, 2020)

The Securities and Exchange Commission today charged the former Corporate Controller of CEB Inc. and his brother-in-law with insider trading in advance of a public announcement about CEB's acquisition for $2.6 billion. The alleged insider trading scheme generated profits of $296,000.

According to the SEC's complaint, William D. Wright learned non-public information about the acquisition of CEB while serving as a senior accounting officer of the company. In the months leading up to the merger announcement, the complaint alleges, Wright repeatedly tipped his brother-in-law, Christopher J. Clark, about the impending acquisition. The complaint alleges that based on the information tipped by Wright, Clark purchased highly speculative, out-of-the-money call options and directed his son to purchase the same options in the son's account. As the date of the announcement approached, Clark allegedly took aggressive steps to fund purchases of additional out-of-the-money CEB options, including liquidating his wife's IRA, nearly maxing out a line of credit and taking out a loan on his car. The options Clark allegedly purchased were so speculative that Clark - alone or with his son - were the only people to buy those options on all but one of the days they traded. As alleged, Clark and his son made profits of more than $243,000 and $53,000, respectively.

The SEC's complaint charges Wright and Clark with violating Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and seeks permanent injunctions, civil penalties, and as to Wright, a bar from serving as an officer or director of a public company.

The SEC's investigation was conducted by Paul Kim, John Lucas, and Deborah Tarasevich with assistance from John Rymas of the SEC Market Abuse Unit's Analysis and Detection Center, who uncovered the suspicious trading. The investigation was supervised by Joseph G. Sansone, Chief of the Market Abuse Unit. Daniel Maher and Olivia Choe are leading the SEC's litigation. The SEC appreciates the assistance of the Financial Industry Regulatory Authority.

Last Reviewed or Updated: May 31, 2023

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