Survey Results: Rule 10b5-1 Plan Practices
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1. Does your company require insiders to sell shares only
pursuant to a Rule 10b5-1 trading plan? (Total responses: n=52)
(select only one) |
| n=2 (3.85%) |
Yes, insiders are required to use Rule 10b5-1 plans in order to
sell shares |
| n=16 (30.77%) |
No, but they are strongly encouraged |
| n=34 (65.38%) |
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=52)
(select only one) |
| n=41 (78.85%) |
Yes, it is subject to prior review and approval by the company
pursuant to the insider trading policy |
| n=7 (13.46%) |
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=4 (7.69%) |
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=52)
(select only one) |
| n=44 (84.62%) |
Yes |
| n=3 (5.77%) |
No |
| n=5 (9.62%) |
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=52)
(select only one) |
| n=7 (13.46%) |
Yes, it is a two week waiting period or less |
| n=12 (23.08%) |
Yes, it is a one month waiting period (or close to it) |
| n=3 (5.77%) |
Yes, it is a two month waiting period (or close to it) |
| n=6 (11.54%) |
Yes, it is a waiting period until the next open window |
| n=19 (36.54%) |
No |
| n=5 (9.62%) |
Not sure, it hasn't come up |
5. Does your company allow insiders to voluntarily terminate a Rule
10b5-1 plan?(Total responses: n=51)
(select only one) |
| n=38 (74.51%) |
Yes |
| n=13 (25.49%) |
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=52)
(select only one) |
| n=16 (30.77%) |
Yes, but only for directors and/or one or more officers |
| n=2 (3.85%) |
Yes, for all directors and employees |
| n=34 (65.38%) |
No |
7. If your company makes public disclosure, how does it do it?
(Total responses: n=20)
(select only one) |
| n=11 (55.00%) |
Form 8-K |
| n=1 (5.00%) |
Press release |
| n=0 (0.00%) |
Website posting |
| n=3 (15.00%) |
Combination of above |
| n=5 (25.00%) |
Other |
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