Half Empty, Half Full: Thoughts on the SEC's Rule 10b5-1 Proposal
January 19, 2022
Episode Notes
- Background on the Rule 10b5-1 proposal (0:25)
- Required cooling-off period (2:28)
- Prohibition on overlapping plans (4:26)
- Limitation on single-trade plans (5:34)
- Good faith requirement (6:52)
- Certification requirement (8:13)
- Quarterly disclosure of adoption and termination of 10b5-1 plans by officers and directors (9:25)
- Form 10b5-1 checkbox on Forms 4 and 5 (9:34)
- Reporting gifts on Form 4 (9:51)
- Disclosure of insider trading policies (10:07)
- Disclosure of options granted to named executive officers or directors within 14 days of company filings and repurchases (10:17)
- John's additional thoughts on the proposed rules (10:47)
- Happenings at CCRcorp that NASPP members might be interested in (12:11)
- Additional resources (12:52)
Resources Mentioned in this Episode
- NASPP blog entries on Rule 10b5-1
- SEC Proposes Amendments to Rule 10b5-1
- Rule 10b5-1 & Buybacks: Practical Impacts of SEC's Proposals (TheCorporateCounsel.net webcast)
- The Latest: Your Upcoming Proxy Disclosures (CompensationStandards.com webcast)
- PracticalESG.com