Because they generally do not have a confidential relationship with the source of the information they receive, however, they do not meet the usual definition of an "insider." [29] House of Representatives rules[30] may however consider congressional insider trading unethical. A 2004 study found that stock sales and purchases by Senators outperformed the market by 12.3% per year.[31] Peter Schweizer points out several examples of insider trading by members of Congress, including action taken by Spencer Bachus following a private, behind-the-doors meeting on the evening of September 18, 2008 when Hank Paulson and Ben Bernanke informed members of Congress about the imminent financial crisis, Bachus then shorted stocks the next morning and cashed in his profits within a week.[32] Also attending the same meeting were Senator Dick Durbin and John Boehner; the same day (trade effective the next day), Durbin sold mutual-fund shares worth $42,696, and reinvested it all with Warren Buffett. Also the same day (trade effective the next day), Congressman Boehner cashed out of an equity mutual fund.[33][34]