Douglas Farr, 44, a commercial litigation attorney and former shareholder at Buchalter in Salt Lake City and a Utah Super Lawyer for 2023 through 2025, has settled Securities and Exchange Commission insider trading charges after purchasing call options in Bridge Investment Group Holdings Inc. less than an hour after learning in a client meeting that Bridge was about to be acquired by Apollo Global Management in a $1.5B all-stock transaction valued at $11.50 per share. Farr had been retained by Bridge on January 29, 2025, to represent the company in a loan dispute with a former employee.
On February 20, 2025, Bridge’s in-house counsel briefed Farr on the pending acquisition during a due diligence meeting. Farr spent $11,685 on Bridge call options that afternoon and the following morning. Four days later, when Bridge and Apollo announced the deal and Bridge’s stock jumped nearly 34%, Farr sold the options for illicit profits of $35,185. The SEC’s cease-and-desist order, issued May 7, 2026, requires Farr to pay $35,185 in disgorgement, $1,255 in prejudgment interest, and a matching civil penalty of $35,185, totaling $71,625, payable in three equal installments of $23,875. The funds go to the US Treasury.
Bridge Retained Farr for a Loan Dispute, Then Briefed Him on the Apollo Acquisition the Same Day
Bridge Investment Group, a Salt Lake City-based real estate investment and asset management firm, had been in exclusive acquisition discussions with Apollo since December 13, 2024, when the two companies signed an exclusivity agreement under which Bridge would negotiate solely with Apollo. During January and February 2025, the companies conducted due diligence and negotiated a draft merger agreement. Bridge retained Farr on January 29, 2025, to handle an unrelated dispute: a loan matter involving a former employee.
On February 20, 2025, Farr met with Bridge’s in-house counsel and its acquisition counsel to discuss the loan dispute as part of due diligence for the pending deal. During that meeting, Farr received material nonpublic information about the acquisition. He owed Bridge a duty of loyalty and confidentiality as its attorney. He owed his law firm a separate duty of confidentiality, having agreed to maintain client information confidentiality when he joined in January 2022. Within the hour, he was buying options.
Farr Spent $11,685 on 269 Bridge Call Options Across Two Days Then Sold Them the Morning of the Announcement
The trading was specific and deliberate. On the afternoon of February 20, less than an hour after the client meeting, Farr purchased 100 Bridge call options with a strike price of $10 expiring July 18, 2025 at $0.25 per contract, and 21 call options with a $7.50 strike expiring July 18, 2025 at $1.20 per contract, for a total of $5,020. The following morning, February 21, he added 38 call options at a $7.50 strike expiring April 17 at $0.90 per contract, 99 more at $10 expiring July 18 at $0.25 per contract, and 11 more at $7.50 expiring April 17 at $0.70 per contract, for a further $6,665. Total investment: $11,685 across 269 call options in two tranches.
Call options on a stock trading at $7.92 with strike prices of $7.50 and $10.00 are a targeted bet on a near-term price spike. The $10 strike options were significantly out of the money, meaning they would only be profitable if the stock rose more than 26% before expiration. Farr knew it would. On February 24, 2025, Bridge and Apollo jointly announced the acquisition at approximately 8:00 a.m. Bridge’s stock moved from $7.92 to $10.60, a 34% single-day gain. Farr sold all his options that morning and pocketed $35,185 in profit.
The Misappropriation Theory Applies Because Farr Traded on Information Belonging to His Client and His Firm
The SEC charged Farr under the misappropriation theory of insider trading, which applies when a person trades on material nonpublic information obtained through a breach of a duty owed to the source of that information. Farr was not a Bridge insider. He was an outside attorney who received confidential information in the course of representing the company. That information belonged to Bridge and its shareholders. By trading on it, Farr breached the duty of loyalty and confidentiality he owed as their attorney, and also breached a separate duty owed to his law firm.
The SEC found that Farr knew, or was reckless in not knowing, that both duties prohibited his trades. The misappropriation theory was established by the Supreme Court in United States v. O’Hagan (1997) and is the primary legal framework through which outside advisers are held liable for trading on client information. Bridge was acquired by Apollo on September 12, 2025, and its common stock was delisted from the New York Stock Exchange at that point. Bridge continues to operate as a standalone platform within Apollo’s asset management business.
The $71,625 Total Penalty Is Paid in Three Installments Over 360 Days with No Fair Fund for Investors
The SEC’s cease-and-desist order requires Farr to pay $35,185 in disgorgement, $1,255 in prejudgment interest, and a matching civil penalty of $35,185, totaling $71,625. Payment is structured in three equal installments of $23,875: the first within 14 days, the second within 180 days, and the third within 360 days plus accrued interest. The entire amount goes to the general fund of the U.S. Treasury, not to harmed investors. The order explains that because the disgorgement does not exceed Farr’s net profits and there is no identifiable pool of damaged investors to compensate, distributing the funds to Treasury is the most equitable alternative. A bankruptcy exception under Section 523(a)(19) of the Bankruptcy Code makes the debt non-dischargeable. The investigation was handled by the SEC’s Philadelphia Regional Office.
Conclusion
Douglas Farr was a shareholder at Buchalter, a Utah Super Lawyer who had built a commercial litigation practice significant enough to attract Bridge Investment Group as a client. The meeting on February 20, 2025 was routine due diligence on a loan dispute. What he did with what he heard in that meeting, buying 269 call options within 90 minutes, is the kind of decision that ends careers. He knew the duties he owed and the SEC found he knew or was reckless in not knowing he was breaching them. The $71,625 total penalty is structured to be payable in installments, but the cease-and-desist order is permanent and the violation is on the public record. For a litigation attorney whose professional reputation depends on client trust, that record is the real consequence.
