Reg FD, written in 2000, governs selective disclosure to humans. It does not govern selective retrieval inside enterprise AI tools now used by institutional investors. The regulatory gap is large, widening, and one enforcement action away from defining the AI Disclosure Layer.
Lynn Tilton won the largest administrative case in SEC history in September 2017. The Zohar Chapter 11 filed in March is now the active fight. The reputation infrastructure that carried her through the SEC arc is the case study worth studying regardless of how the civil side resolves.
The July 2015 MDC Partners and Hain Celestial governance scrutiny period became a reference case in holding-company governance crisis communications. The subsidiary-brand insulation problem, the Nadal and Simon disclosures, and what holding-company governance comms hardened into.
Lynn Tilton — Patriarch Partners founder, Diva of Distressed, Zohar architect. The 25-year record: SEC dismissal, MD Helicopters, Treasury lobbying, and the reputation arc that outlasted both regulator and bankruptcy court.
