So, a secret deal that allows someone to obtain shares of a publicly traded company based on meeting secret targets? Interesting. Did he sell those shares based on inside information about ratings or targets?
What is most relevant here are The Insider Trading Sanctions Act of 1984 and The Insider Trading and Securities Fraud Enforcement Act of 1988 . The Insider Trading Acts allow the Securities and Exchange Commission ("SEC") to sue individuals who
trade securities based on material, non-public information (insider trading) or who disclose such information to others facilitating improper trading (stock tipping). The courts may impose penalties up to three times the profit gained or the loss avoided as a result of illegal conduct. In addition, these acts could give rise to criminal sanctions.
Both Howard Stern and his buddy Don Buchwald look fishy.