SEC Grants No-Action Relief for Those Seeking to Aggregate Transaction Reporting under Section 16(a)

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The SEC’s Office of Chief Counsel, Division of Corporation Finance, issued a no-action letter on June 25, 2008, granting relief to Section 16(a) reporting persons that wish to aggregate reporting of qualifying same-day, same-way open market transactions on Form 4 and Form 5 under Section 16 (a) of the Securities Exchange Act of 1934. The no-action letter can be found at:

http://www.sec.gov/divisions/corpfin/cf-noaction/2008/scsgp062508-sec16.htm.

The no-action letter reverses the Staff’s prior position, which required reporting persons to enter each sale or purchase transaction on a separate line of the applicable form. In connection with issuing the no-action letter, the Staff deleted its prior position from the Compliance and Disclosure Interpretations (formerly, interpretation number 133.08).

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