Page 26 - 期货和衍生品行业监管动态（2024年3月）

期货和衍生品行业监管动态

The complaint alleges that Natrop and Renner, who were friends and business

associates of Cook’s, purchased Tallgrass call options on August 8 and 9, 2019, which

resulted in illicit profits of $43,862 for Natrop and $13,520 for Renner. The complaint

further alleges that Cook tipped Rudolph while the two were in the Bahamas

celebrating Rudolph’s birthday on Rudolph’s yacht and that Rudolph purchased

Tallgrass stock on August 6, 2019, which resulted in illicit profits of $31,035. The

complaint also alleges that Cook tipped Williams, his long-time friend and personal

accountant, and that Williams purchased call options on August 19 and 21, 2019,

which resulted in illicit profits of $463,000.

Following the August 27 announcement, which saw Tallgrass shares increase by

36 percent, Cook served for several months as chair of a Tallgrass Conflicts

Committee tasked with assessing Blackstone’s offer and negotiating the final terms of

the transaction. In connection with this role, Cook allegedly learned material

nonpublic information about the status of the negotiations that he communicated to

Williams, who purchased Tallgrass stock in a Cook family trust account over which

he had trading authority, resulting in $88,800 of illicit profits for Cook. The complaint

further alleges that, on December 10, 2019, while on vacation in Chile, Cook tipped

Williams more material nonpublic information about the status of the negotiations,

and Williams purchased more call options in his personal account, resulting in

additional illicit profits of $61,525.

“As our complaint alleges, Roy Cook took advantage of his position as a

Tallgrass director to repeatedly enrich himself and his friends,” said Mark Cave,

Associate Director of the SEC’s Division of Enforcement. “We will hold accountable

board members and others who misuse inside information for their own benefit and

violate the trust placed in them by shareholders.”

The SEC complaint, filed in U.S. District Court for the Eastern District of

Wisconsin, charges the defendants with violating the antifraud provisions of the

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