Simpson Thacher’s article: “New rules are coming into effect: what public companies need to do now to implement the new SEC insider trading rules” recaps the SEC’s recently adopted rule on Rule 10b5-1 plans and insider trading policies (initially reported on here) and offers sound action items for companies to consider to comply or prepare for compliance (as the case may be) and to minimize perceived negative option grant disclosures. Suggestions include—among other things—reviewing insider trading policies and procedures for conformance with the rule and incorporation of additional requisite internal oversight; requesting updated forms of 10b5-1 plans from brokers; consolidating information on Rule 10b5-1 plans and non-rule 10b5-1 arrangements; educating directors and employees; and considering an option grant policy or revised grant policy in response to the award timing disclosure requirements.
See our recent reports: “Rule 10b5-1 Plans: Risk Mitigation” and “Rule 10b5-1 and Insider Trading Disclosure FAQs” and additional information & resources on our Insider Trading / Section 16 / Rule 10b5-1 page. This post first appeared in the weekly Society Alert!