White & Case’s US Public Company Advisory Group has conducted its second annual survey of publicly filed insider trading policies to assess trends with respect to insider trading policy terms. Calendar-year end public companies were first required to publicly disclose their insider trading policies in 2025 following recent SEC rule changes, and as companies approach their second year with this disclosure, it is a good time to review policy terms and confirm whether any changes would be appropriate. Key findings and considerations from our White & Case survey are found in this alert.
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