Section 16 Reporting Update: SEC Allows Aggregate Form 4 and Form 5 Reporting of Same-Day, Same-Way Open Market Transactions
Date: 07/01/08
On June 25, the Securities and Exchange Commission issued a no-action letter to the Society of Corporate Secretaries & Corporate Governance Professionals indicating that it would allow "aggregate reporting of sameday, same-way open market purchases or sales on Form 4 and Form 5 under Section 16(a) of the Securities Exchange Act of 1934."1 This effectively relaxes the current rule, embodied in Instruction 4(a)(ii) to Form 4 and Form 5, whereby Section 16 filers were required to report all transactions for different prices on separate lines.2
This memorandum is for general information purposes only and is not intended to advertise our services, solicit clients or represent our legal advice.
Download: Section 16 Reporting Update: SEC Allows Aggregate Form 4 and Form 5 Reporting of Same-Day, Same-Way Open Market Transactions (PDF, 116.13 K)
Related Attorneys:
Jonathan I. Mark,
John J. Schuster
Related Practices:
Corporate Governance & Investigations,
Corporate
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