September 17, 2002
Sullivan & Cromwell (in a law firm client memo dated 9/12) has reversed its initial position that cashless exercise programs should be suspended until more guidance was available. Now, S&C believes that all forms of cashless exercise programs are permissible – as well as indemnification advances. As it was last month, the S&C memo may be a harbinger of a sea change in what law firms advise on these topics. This memo is located at http://www.realcorporatelawyer.com/Features/SullivanCromwell-Section402.pdf.