A self-directed IRA investor who sued PNC, claiming the bank leaked false info to the SEC—sparked a high‑stakes legal showdown

Gibson alleged reputational damage and accused PNC of violating fiduciary duties tied to his retirement account

PNC used Georgia’s anti-SLAPP law to knock out Gibson’s defamation claims—raising pivotal issues about free-speech protections

PNC argued that it was simply following a subpoena—not acting as Gibson’s fiduciary—even though it held his IRA.

Gibson claimed PNC improperly hid key documents—PNC insisted privilege protected them. The court mostly disagreed. 

The appellate court ruled in favor of PNC, ordering it to collect attorney fees under the statewide anti-SLAPP rule.

Judges rejected Gibson’s claim to hidden documents, ruling PNC wasn’t a fiduciary under Georgia law. 

This case defines how banks can—or can’t—be held liable when handling client IRA data amid subpoenas.