New conditions to the availability of the affirmative defense under the Rule 10b5-1(c)(1), including a cooling-off period before trading can begin for directors, officers, and other persons (other than issuers) -
New certification and disclosure requirements regarding issuers’ insider trading policies and regarding the adoption and termination (including modification) of Rule 10b5-1 and certain other trading arrangements by directors, officers, and issuers -
Please see full publication below for more information.