Answer the questions directly and concisely. Do not repeat the questions. Write legibly. A mere "Yes or "No" answer will not be given any credit.

II

Mr. P, the President of JKL, Inc. which shares are listed in the Philippine Stock Exchange, was notified that the corporation has just been awarded a 5,000,000,000.00 construction contract by a reputable private company. Before this information could be disclosed to the public, Mr. P called his stockbroker to purchase 20,000 shares of JKL, Inc. He also mentioned the transaction to his brother, Mr. B. Mr. B, who was not involved at all in the business of JKL, Inc., also bought 50,000 shares of JKL, Inc. because of the tip disclosed to him by Mr. P.

(a) Is the information disclosed by Mr. P to Mr. B considered as material nonpublic information for purposes of insider trading? Explain.

(b) Should Mr. P and Mr. B be held liable for insider trading? Explain.