Two days after a private -- and possibly questionable -- meeting between analysts and the CFO of Siebel Systems ( SEBL), the company's executive vice president sold about 34% of his shares in Siebel.

Executive Vice President David Schmaier grossed $1.9 million when he sold 200,000 shares of Siebel at $9.68 a share on May 2, according to documents filed with the Securities and Exchange Commission. Schmaier still holds 379,4222 Siebel shares, according to the SEC.

Although the transaction was a relatively large one, it would normally be seen as unremarkable. However, the SEC is currently looking into a meeting in New York on April 30 between CFO Ken Goldman and analysts from several still unidentified Wall Street firms. The meeting is under review by the SEC for possible violations of Regulation Fair Disclosure, a rule that prohibits public companies from selectively releasing material information.

A company spokesman said nothing was disclosed at the meeting that had not already been made public.

On May 1, the day after the meeting, Siebel shares rose 68 cents, or 7.5%, to $9.66 on volume that was nearly four times normal. Schmaier sold his shares the following day.

A spokesman for Siebel said that Schmaier was not aware of the dinner meeting when he sold his stock, and there was nothing improper about the transaction. Schmaier, an insider, sold the shares privately, and notified the SEC of the transaction. Because his broker filed the forms via paper, there was a (perfectly legal) delay in the information being disseminated to services that resell SEC filings.

In a written statement, the company said: "Siebel will not be conducting one-on-one investor meetings at any of the upcoming financial events as a result of the latest SEC inquiry of Siebel Systems. Siebel is happy to participate in these financial conferences and other investor events as long as the sessions (i.e., presentations, question-and-answer breakouts, other investor meetings, etc.) are being Web cast."

On Monday, Siebel was down 27 cents, or 2.8%, to $9.26 a share on volume of 15.3 million shares, roughly 1 1/2 times normal.