On Friday, the SEC's Division of Corporation Finance posted five new Compliance and Disclosure Interpretations on the amendments to Rule 10b5-1. Exchange Act Rules: Questions 120.29 (re: cooling off period); 120.30 (re: availability of affirmative defense in specific scenario); and 120.31 (re: Form 4 check box in relation to pre-existing trading plans); and Regulation S-K: 133A.01 (re: applicability of plan termination disclosure), and 133A.02 (re: covered trading arrangements for purposes of adoption / termination disclosure). Exchange Act Rule C&DI 120.31 is also new Question 135.04 under the Exchange Act Section 16 and Related Rules and Forms interpretations. We reported on Questions 120.26, 120.27, and 120.28 (posted in May) here.
The new C&DIs are summarized in this Cooley post.