New Insider Trading Plan C&DIs and a Tip for Keeping Up with CorpFin Developments

In our workshops we discuss the various avenues through which CorpFin provides reporting and filing guidance.  Perhaps more importantly, we also review how to keep current with new guidance.  One very helpful tool is the “What’s New” section of CorpFin’s homepage (located on right side of page).

While this “What’s New” box looks like a heading for the column below, it is actually a link to this helpful webpage where CorpFin usually announces new guidance:

As you can see, on August 25, 2023, CorpFin issued several new C&DIs related to the recent Insider Trading Arrangements Final Rule.  The new C&DIs, among other things, clarify that the new check box on Form 4 to indicate that a trade was conducted pursuant to a plan does not apply to plans adopted before the Final Rule’s effective date, and that the cooling-off period provision related to “[t]wo business days following the disclosure of the issuer’s financial results in a Form 10-Q or Form 10-K for the completed fiscal quarter in which the plan was adopted” does not include the date of filing.

As always, your thoughts and comments are welcome!

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