TheCorporateCounsel.net

As evident from our blackout/window period survey last year, blackout periods is a topic that folks love to benchmark (see last year’s results). So I just posted another survey on these periods with five questions – please go to the top of TheCorporateCounsel.net home page and take this new survey, which addresses:

– Does your company ever impose a “blanket blackout period” for all or a large group of employees?

– How does your company’s insider trading policy define those employees subject to a blackout period?

– Does your company allow employees (that are subject to blackout) to gift stock to a charitable, educational or similar institution during a blackout period?

– Does your company allow employees (that are subject to blackout) to gift stock to a family member during a blackout period?

– Are your company’s outside directors covered by blackout or window periods and preclearance requirements?

How to Search the SEC Comment Letter Database

The SEC has posted these instructions on how to search the comment letter database. I think the instructions are likely to be tweaked as the database is honed – and don’t forget to listen to next Thursday’s webcast – “How to Navigate Tricky Confidential Treatment Requests” – to hear SEC Corp Fin Deputy Director Shelley Parratt speak about searching the database and related issues.

Award-Winning Blog?

Okay, as we head into the waning days of a close contest, my blog is tied for first place in the “Favorite Practice Area Blog” category. If ya like reading this thing, go ahead and do me a “solid” and vote for the blog. To do so, you will have to first join (at no cost) TechnoLawyer – and then you should send an email to tlballot@peerviews.com (cut and paste this addressee) with this message in the body: “For #5 Favorite Practice Area Blog – I vote for TheCorporateCounsel.net Blog.”

If you can’t bear the thought of joining another free site, send the email anyways and perhaps they will count the vote out of the kindness of their heart. [Note that I have belonged to TechnoLawyer for quite a while and very rarely receive emails from them – so joining shouldn’t hurt your inbox.] Voting ends at the end of this Friday!

Q&A on Option Expensing

FAS 123(R) requires companies to recognize compensation expense for all forms of stock compensation, including stock options. Even with the SEC’s delay, the effective date will be here before you know it, yet many practice-related questions remain unanswered.

To help prepare for the transition, here is a panel of experienced practitioners to answer your questions on the standard on tomorrow’s NASPP webcast: “Q&A on FAS 123(R).” You can submit questions in advance for Paula Todd of Towers Perrin and Reginald Oakley of the FASB to answer.