The UK Financial Services Authority (FSA) has concluded that hedge fund founder David Einhorn and his Greenlight Capital Inc. (Greenlight) engaged in impermissible “insider dealing” when they sold shares of British pub owner Punch Taverns Plc (Punch) immediately following a conference call with Punch management.  The FSA concluded that, even though Einhorn had refused to sign a nondisclosure agreement before the call and believed that he had not received inside information, Einhorn should have refrained from trading in Punch shares because he should have understood that he had received inside information about the terms and timing of a proposed equity issuance by Punch.  We summarize the FSA’s conclusions and the rationale for its actions.  See generally “Use by Hedge Fund Managers of Restricted Lists, Watch Lists and Ethical Walls to Prevent Insider Trading Violations,” Hedge Fund Law Report, Vol. 4, No. 37 (Oct. 21, 2011).