Survey Results: Rule 10b5-1 Plan Practices
 1. Does your
company require insiders to sell shares only pursuant to a Rule 10b5-1
trading plan? (Total responses: n=35)
(select only one) |
| n=0 (0.00%) |
Yes, insiders are required to use Rule 10b5-1 plans in order to
sell shares |
| n=11 (31.43%) |
No, but they are strongly encouraged |
| n=24 (68.57%) |
No, and they are not explicitly encouraged |
| n=0 (0.00%) |
Not sure, it hasn't come up |
2. Does your
company review and approve each insider's Rule 10b5-1 trading plan?
(Total responses: n=34)
(select only one) |
| n=31 (91.18%) |
Yes, it is subject to prior review and approval by the company
pursuant to the insider trading policy |
| n=2 (5.88%) |
Yes, but only the template plan is reviewed and not the actual
trading schedule |
| n=0 (0.00%) |
No, but we have a broker that we require to be used and have
reviewed that brokers template |
| n=1 (2.94%) |
No, and there is no requirement to go through a specific broker
|
3. Does your
company allow sales of shares through Rule 10b5-1 trading plans during
blackout periods? (Total responses: n=35)
(select only one) |
| n=32 (91.43%) |
Yes |
| n=1 (2.86%) |
No |
| n=2 (5.71%) |
Not sure, it hasn't come up |
4. Does your
company require a waiting period between execution of Rule 10b5-1
trading plans and time of first sale? (Total responses: n=34)
(select only one) |
| n=5 (14.71%) |
Yes, it is a two week waiting period or less |
| n=15 (44.12%) |
Yes, it is a one month waiting period (or close to it) |
| n=4 (11.76%) |
Yes, it is a two month waiting period (or close to it) |
| n=4 (11.76%) |
Yes, it is a waiting period until the next open window |
| n=6 (17.65%) |
No |
| n=0 (0.00%) |
Not sure, it hasn't come up |
5. Does your
company allow insiders to voluntarily terminate a Rule 10b5-1 plan?
(Total responses: n=33)
(select only one) |
| n=27 (81.82%) |
Yes |
| n=6 (18.18%) |
No, only terminations dictated by the trading plan are allowed
|
6. Does your
company make public disclosure of the insiders' Rule 10b5-1 trading
plans? (Total responses: n=34)
(select only one) |
| n=5 (14.71%) |
Yes, but only for directors and/or one or more officers |
| n=2 (5.88%) |
Yes, for all directors and employees |
| n=27 (79.41%) |
No |
7. If your company
makes public disclosure, how does it do it? (Total responses:
n=12)
(select only one) |
| n=6 (50.00%) |
Form 8-K |
| n=1 (8.33%) |
Press release |
| n=1 (8.33%) |
Website posting |
| n=1 (8.33%) |
Combination of above |
| n=3 (25.00%) |
Other |
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|
