The SEC yesterday announced that it has adopted the Dodd-Frank hedging policy disclosure rules and issued a request for comment on quarterly reporting. We will provide additional information in the form of client memos, but preliminary information based on the fact sheets published includes:
Hedging Rules. Compliance is required in proxy statements during fiscal years beginning on or after July 1, 2019. Companies must disclose any practices or policies it has adopted about the ability of its employees (including officers) or directors to buy securities or other financial instruments, or otherwise engage in transactions, that hedge or offset, or are designed to hedge or offset, any decrease in the market value of equity securities granted as compensation, or held directly or indirectly by the employee or director.