Trading Plans

News & Analysis as of

CFTC Proposes Supplement to Aggregation Proposed Rules for Position Limits

On September 22, 2015, the Commodity Futures Trading Commission (“CFTC”) issued for public comment a supplement (the “Supplemental Aggregation Proposal”) to its proposed aggregation rules for position limits for related...more

ESMA Update on Waivers From MiFID Pre-Trade Transparency Requirements: August 2015

On August 26, 2015, the European Securities and Markets Authority (ESMA) published an updated version (dated August 21, 2015) of the waiver document (ESMA/2011/241g) that sets out its assessment of applications for waivers...more

FERC Commissioner Moeller Convenes Public Meeting Focusing on Resolving Natural Gas Supply Challenges for Electric Generators

Commissioner Philip Moeller of the Federal Energy Regulatory Commission (FERC) held a public meeting on September 18, 2014 to discuss ideas to facilitate and improve the way in which natural gas is traded and to explore the...more

CBOE Reminds Trading Permit Holders to Notify Exchange of Disciplinary Actions

The Chicago Board Options Exchange (CBOE) issued a Regulatory Circular reminding Trading Permit Holders (TPH) that CBOE Rule 4.9 requires every TPH to notify the CBOE in writing of any disciplinary action taken by other...more

Best Laid Plans Gone Awry: Practices for Rule 10b5-1 Trading Plans

Rule 10b5-1 trading plans are in the limelight due to investigations initiated by U.S. Attorney’s Offices and the SEC into possible abuses by corporate executives of such plans. Now, more than ever, companies and their boards...more

"Getting Back to Basics with Rule 10b5-1 Trading Plans"

In late 2012, The Wall Street Journal published a number of articles that analyzed the trading practices of certain public company executives, in many cases under trading plans that were entered into in accordance with the...more

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