Recent SEC Enforcement Action Involves "Big Boy" Letters

On June 7, 2007, the New York office authored an Alert Memo entitled, “Recent SEC Enforcement Action Involves ’Big Boy’ Letters.” The Alert Memo discusses last week’s settled enforcement action against Barclays Bank PLC for alleged insider trading violations, in which the SEC expressly noted the use of ’Big Boy’ letters, potentially indicating an interest in this controversial practice. The Alert Memo summarizes the key points of this action.