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


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:

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).

See legal update for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morrison & Foerster LLP | Attorney Advertising

Written by:


Morrison & Foerster LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.