Late last year, the Securities and Exchange Commission (SEC) adopted new disclosure requirements with respect to insider trading policies and procedures. These new disclosure requirements are codified in Item 408(b) of Regulation S-K. It is important to note that SEC regulations do not specifically govern a registrant's insider trading policies themselves. Rather, SEC regulations only govern the disclosure of whether a registrant has adopted an insider trading policy (the Policy). As a result, registrants have some flexibility in crafting their insider trading policies and procedures so long as they are designed to assist directors, officers, and other employees in complying with the insider trading prohibitions and other requirements of the federal securities laws and regulations. Continue reading >