Survey Results: Insider Trading Policies: Pledges & Margin Accounts
 1. Does your
company's insider trading policy prohibit insiders from pledging their
company shares? (Total responses: n=53)
(select only one) |
| n=20 (37.74%) |
Yes |
| n=33 (62.26%) |
No |
2. If your
company's insider trading policy does not prohibit pledges, does your
company: (Total responses: n=27)
(select all that apply, may total more than 100%) |
| n=15 (55.56%) |
Discourage or advise against pledges |
| n=18 (66.67%) |
Require preclearance for pledges |
| n=5 (18.52%) |
Include criteria that must be met for pledges (e.g., financial
wherewithal, limited to a specified percentage of holdings) |
3. If your
company's insider trading policy requires preapproval or satisfaction of
certain criteria for pledges, who makes that determination?
(Total responses: n=24)
(select all that apply, may total more than 100%) |
| n=0 (0.00%) |
CEO |
| n=1 (4.17%) |
CFO |
| n=19 (79.17%) |
GC |
| n=1 (4.17%) |
Board Committee |
| n=4 (16.67%) |
Other |
4. Does your
company's insider trading policy prohibit insiders from using margin
accounts with their company shares? (Total responses: n=52)
(select only one) |
| n=21 (40.38%) |
Yes |
| n=31 (59.62%) |
No |
5. If your
company's insider trading policy does not prohibit margin accounts, does
your company: (Total responses: n=23)
(select all that apply, may total more than 100%) |
| n=15 (65.22%) |
Discourage or advise against margin accounts |
| n=13 (56.52%) |
Require preclearance for margin accounts |
| n=4 (17.39%) |
Include criteria that must be met for margin accounts |
6. If your
company's insider trading policy requires preapproval or satisfaction of
certain criteria for margin accounts, who makes that determination:
(Total responses: n=17)
(select all that apply, may total more than 100%) |
| n=0 (0.00%) |
CEO |
| n=2 (11.76%) |
CFO |
| n=15 (88.24%) |
GC |
| n=0 (0.00%) |
Board Committee |
| n=2 (11.76%) |
Other |
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