Survey Results: More on Regulation FD Practices
Last year, we conducted a
survey on Regulation FD practices.
Since we continue to get so many inquiries on this topic, the survey
below asks the same questions to gauge changes in this area (with an
additional question about Web positions):
1. Our company posts information on its corporate website and takes
the position that this is sufficient to satisfy Reg FD: (Total responses: n=53)
(select only one) |
| n=2 (3.77%) |
Yes, our company takes this position for anything posted on
its corporate website |
| n=15 (28.30%) |
It depends, our company takes this position for certain items
posted on its corporate website (but not all) |
| n=36 (67.92%) |
No, our company does not yet take this position |
2. Our company has a written policy addressing Reg FD practices: (Total
responses: n=53)
(select only one) |
| n=3 (5.66%) |
Yes, and it is publicly available on our website |
| n=32 (60.38%) |
Yes, but it is not publicly available on our website |
| n=8 (15.09%) |
No, but we are in the process of drafting such a policy |
| n=10 (18.87%) |
No, and we do not intend to adopt such a policy in the near
future |
3. Regarding reaffirmation of earning announcements, our company
uses one of the following rules of thumb regarding private
reaffirmations: (Total responses: n=51)
(select only one) |
| n=31 (60.78%) |
We do not allow private reaffirmation |
| n=4 (7.84%) |
Rule of thumb allowing for private reaffirmations of one week
or less |
| n=7 (13.73%) |
Rule of thumb allowing for private reaffirmations of one to
two weeks |
| n=5 (9.80%) |
Rule of thumb allowing for private reaffirmations of two to
three weeks |
| n=4 (7.84%) |
We permit private reaffirmations - but never use a rule of
thumb, instead we require confirmation of no material change with
CEO, GC, etc. |
4. At our company, our CEO and other senior managers: (Total
responses: n=60)
(select all that apply, may total more than 100%)
|
| n=4 (6.67%) |
Are not permitted to meet privately with analysts |
| n=21 (35.00%) |
Are only permitted to meet privately with analysts so long as
someone else accompanies them (such as general counsel or IR
officer) |
| n=11 (18.33%) |
Are permitted to meet privately with analysts after briefing
by IR officer, general counsel, etc. |
| n=11 (18.33%) |
Are only permitted to meet privately with analysts during
certain designated times |
| n=20 (33.33%) |
Are not permitted to talk about certain topics |
|
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