Data from the most three recent Domestic Stock Plan Administration Surveys co-sponsored by the NASPP and Deloitte Consulting across public companies of various sizes and industries, courtesy of WilmerHale’s 2021 IPO Report (p 22), reveals that the categories of persons regularly subject to scheduled quarterly blackout periods have remained relatively consistent (+/15%) over the past six years, as follows:
There has been greater variability over that same period in the types of non-10b5-trading plan transactions prohibited during those blackout periods; however, most companies have continued to prohibit broker-assisted cashless option exercises, stock-for-stock option exercises, share withholding upon option exercises, and cash option exercises.
Equally informative is the benchmarking data pertaining to Rule 10b5-1 trading plans. A table on page 26 of the report addresses plan review and approval requirements, eligibility, waiting periods, plan terms, plan scope, and plan modification and termination policies/practices.
Watch for much more benchmarking data on Rule 10b5-1 plan practices and policies in our forthcoming collaborative Society/Wilson Sonsini Goodrich & Rosati/Morgan Stanley/Ebullience Inc. report based on a recent Society member survey, which will refresh the frequently consulted Society member 2015 survey data.
Access additional resources on our Insider Trading/Section 16 page.
This post first appeared in the weekly Society Alert!