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CFA INSTITUTE ETHICS IN PRACTICE: Disclosures - Case 11 CASE STUDY Greenfield is the chief financial officer of HumanaHealthMD, a biotech firm that researches, develops,
CFA INSTITUTE ETHICS IN PRACTICE: Disclosures - Case 11 CASE STUDY Greenfield is the chief financial officer of HumanaHealthMD, a biotech firm that researches, develops, and commercializes pharmaceutical drugs for women's health issues. Humana submits a new drug application to government regulators for a promising new drug for treating hormone deficiency. Two meetings scheduled with regulators to discuss the drug are postponed when the regulator states that unspecified deficiencies with the drug make such discussions premature. The public announcement of each meeting postponement results in a decline of more than 10% in the company stock. When the meeting between regulators and company executives finally happens, Humana presents yet-to-be published preliminary test data with favorable indicators for the drug. The regulators react positively and give Humana preliminary regulatory approval contingent on further studies. After the meeting, six sell-side research analysts covering Humana inquire with Greenfield about the meeting. Greenfield responds by email and indicates that he believes the meeting with regulators was "very positive and productive" and that the company was "pleasantly surprised by the reaction of the regulators. Greenfield does not share the favorable preliminary test data with the analysts. After the emails to the analysts, the stock price of the company increases 19%. Greenfield's actions are A. appropriate because Greenfield does not share the unpublished preliminary test data with the analysts but restricts his comments to the general tenor of the meeting. B. appropriate because Greenfield responds to questions from research analysts covering the company C. appropriate because Greenfield communicates with all six research analysts covering the company. D. inappropriate. E. none of the above
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