A Comprehensive Look at Insider Trading Policies: The Litigator’s Perspective
May 20, 2021 •
Our guests – DLA Piper’s Deborah Meshulam and King & Spalding’s Dixie Johnson – dig really deep into everything you need to know about insider trading policies, including:
- Is a policy required and if so, by what statute/rule/reg and what is the extent of what’s required (as opposed to advised)?
- Definition of “Material Non-Public Information”
- Scope / Covered persons & transactions / Differences for Section 16 persons
- How the blackout period works
- Exceptions to the policy
- 10b5-1 plans
- Pre-Clearance & inquiries / Who should pre-clear / Reporting of violations/ Attorney-client privilege issues for communications and records
- Sanctions & penalties
- Acknowledgement
- Effective communication of the policy
- How do you deal with “hot topics” – like cybersecurity breaches? Do you add them into the policy or address them in another manner?
For many more Vid-Guides dealing with corporate & securities law, corporate governance, E&S issues and more – particularly if you want to review any Vid-Guides referred to during this Vid-Guide – see the list of Vid-Guides spread throughout these categories:
- Corporate Governance
- Proxy Season
- Executive Pay
- ’34 Act/Other
- ’33 Act/Deals
- Sustainability/E&S
- Career Advice
- Fun Party
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