The SEC final rules that require companies to disclose practices
or policies on the ability of employees or directors to engage in
hedging transactions with respect to company equity securities held
or granted as compensation were published in the Federal Register. The
effective date for the final rules is March 8, 2019.
If the company does not have any policies or practices on the
matter, then the company must disclose that fact or note that
hedging transactions are generally allowed. The final rules also
specify that the equity securities for which disclosure is required
include equity securities of the company, any parent or subsidiary
of the company, or any subsidiary of any parent of the company. As
previously covered, the final rules implement Exchange Act Section 14(j), which was enacted
by Section 955 of the Dodd-Frank Act.
