SEC Rules Relating to Disclosure of Heding Policies
By , , , on

On July 1, 2019, SEC rules regarding the disclosure of hedging policies or practices became effective.  New Item 407(i) of Regulation S-K requires public companies to provide, among other items:

  • A summary of the company’s hedging policies or the full text of such policies;
  • The categories of hedging transactions that are either specifically allowed or disallowed;
  • The effect of hedging policies on all employees and directors; and
  • If no hedging policy is in effect, a statement that no such policy is in effect.

The new rule applies to proxy statements for fiscal years beginning on or after July 1, 2019, with the exception of smaller reporting companies and emerging growth companies, who must begin making the disclosures for fiscal years beginning on or after July 1, 2020.

Tags: Hedging, SEC, Securities Law
Share +

KMK Law articles and blog posts are intended to bring attention to developments in the law and are not intended as legal advice for any particular client or any particular situation. The laws/regulations and interpretations thereof are evolving and subject to change. Although we will attempt to update articles/blog posts for material changes, the article/post may not reflect changes in laws/regulations or guidance issued after the date the article/post was published. Please consult with counsel of your choice regarding any specific questions you may have.

ADVERTISING MATERIAL.

© 2022 Keating Muething & Klekamp PLL. All Rights Reserved

Subscribe

Jump to Page
Close