White & Case’s “Equity Grant Procedures and Guidelines for the Granting of Equity Awards” offers tailorable, sample equity grant procedures and guidelines that support companies’ compliance with new Item 402(x) of Regulation S-K (addressing disclosure of equity awards in relation to material nonpublic information) (see our report here) and Staff Accounting Bulletin No. 120. The instructive memo also includes an illustrative timeline for calendar year companies that suggests the best time to make grants relative to the company’s earnings releases and periodic SEC filings.
This post first appeared in the weekly Society Alert!