Executive Stock Sales Are Under Scrutiny. Here’s What Regulators Are Interested In.

The regulators have made it clear that they are revisiting Rule 10b5-1 Executive Stock Sale Plans with a view of “tightening” them up.  While we cannot, with specificity, anticipate what the changes will be in connection with existing plans and in connection with new plans, it may be advisable to consider programs which provide for periodic sales or periodic sales with specified prior targets. Such an approach could be expected to make the plans less likely to need to be changed or attacked in the future.