The penalties are so stiff for a lot of infractions, there is far less attempts to workaround the letter of the rules than you would immediately expect.
There's also classes of in-person meetings with externals that you need pre-approval permission to attend and to write up what was discussed after the fact.
Like people at asset management firms attending a dinner with a broker.
Another example, at a hedge fund I worked, emails, meetings or phone calls to public companies required pre-approval from compliance, and for them to be on the email or call. The emails would also require a preface reminding the moron on the other side that you are a hedge fund and they should not provide you with any material non-public info.
It wasn’t about regulation, but protectionism. If you want to do business with us, you need to hire people to deal with us - people we approve of, or no access.
This was in an unregulated industry, with strong protectionist instincts (Hollywoods movie industry).
Couldn’t these sorts of “in person only” rules also be a protectionist gatekeeping technique?
If you are allowed to be off the record only in person, this seems like the perfect commercial real estate subsidy program from the federal government.