A former attorney with law firm Cozen O’Connor has agreed to pay $20,004 and be permanently barred from appearing before the Securities and Exchange Commission (SEC) to settle charges he traded on inside information on a corporate client.
The SEC alleged William Gericke, of West Chester, Penn., conducted a confidential conflicts check on Liberty Property Trust (LPT) in October 2019. During the check, Gericke learned nonpublic material information regarding a potential merger involving LPT and Prologis, a public company based in San Francisco.
The day after he conducted the check, Gericke allegedly bought 1,000 shares of LPT. After the merger was announced, LPT’s stock value increased by more than 13 percent, and Gericke sold the stock at a profit of $10,002, according to the SEC.
“By purchasing LPT stock while in possession of confidential information regarding the impending merger, Gericke misappropriated material nonpublic information that he obtained in the course of his employment as an attorney, and breached a duty of trust and confidence he owed to his law firm and LPT,” the SEC said in its order.
In addition to the fine, Gericke, who did not admit nor deny the allegations against him, agreed to the entry of an order “permanently denying him the privilege of appearing and practicing before the SEC as an attorney, which prohibits Gericke from representing clients in SEC matters, including investigations, litigation, or examinations, and from advising clients about SEC filing obligations or content,” the agency said in its administrative proceeding Friday.
The SEC did not identify Cozen O’Connor as Gericke’s employer in its order—only saying he was “employed by a large international law firm” from 1997 until August 2021. The agency noted Gericke did not inform the firm about his purchase of the stock.
A spokesperson for Cozen O’Connor said the firm was aware of the SEC’s administrative proceeding against its former employee.
“The actions that were alleged by the SEC against Mr. Gericke violated law as well as the firm’s policies and procedures that all employees are obligated to follow,” the spokesperson said. “When we became aware of Mr. Gericke’s activity, we took prompt and appropriate action, including cooperating with the SEC. We are glad that this matter has been resolved and that the behavior of the former employee resulted in no harm to our client.”