I’m not informed even in the laws of my own country, let alone some other country like USA. That said, based on this Wikipedia link, it would - because for a small time period, they didn’t disclose the info at large, but only to a handful of individuals.

And regardless of the applicability of the law, on the best hypothesis it’s Reddit Inc. doing stupid shit again, screwing with the userbase for no good reason, because whoever is in charge of the company is as insightful as a brick.