TheCorporateCounsel.net

We recently wrapped up our Quick Survey on analyst “quiet period” practices. Below are our results:

1. Our company:
– Has a separate policy addressing quiet periods for analysts – 12.1%
– Has a policy addressing quiet periods for analysts, but it is part of our Regulation FD policy – 39.4%
– Has a policy addressing quiet periods for analysts, but it is part of our insider trading policy – 12.1%
– No, our company doesn’t have a policy addressing quiet periods for analysts – 36.4%

2. Our quiet period policy for analysts provides that the quiet period commences:
– More than three weeks before an earnings announcement – 10.4%
– Between two-three weeks before an earnings announcement – 25.0%
– Less than two weeks before an earnings announcement – 8.3%
– More than two weeks before a quarter ends – 8.3%
– Between one-two weeks before a quarter ends – 22.9%
– One week or less before a quarter ends – 6.3%
– Exactly when a quarter ends – 14.6%
– Sometime after a quarter ends – 4.2%

3. Our quiet period policy for analysts is:
– Has the exact same parameters as our trading blackout period (ie. when insiders are prohibited from making trades in the company’s stock) – 53.6%
– Has different parameters than our trading blackout period, as the quiet period for analysts commences at least two weeks earlier – 8.9%
– Has different parameters than our trading blackout period, as the quiet period for analysts commences between one-two weeks earlier – 5.4%
– Has different parameters than our trading blackout period, as the quiet period for analysts commences later than the blackout period – 14.3%
– We don’t have a quiet period policy for analysts – 17.8%

Please take a moment to participate in our new “Quick Survey on Insider Trading Policies: Hedging/Other Prohibitions.”

Don’t forget that the deadlines for Forms 5, 13G, and 13F this year falls on Tuesday, February 17th since Monday is a holiday.

Board Portal Developments

In this podcast, Joe Ruck of BoardVantage explains how the board portal processes have changed to make them more effective, including:

– What has changed since we spoke last year?
– How is the market for board portals evolving?
– Any surprises in terms of how boards use them lately?
– What are the latest developments for BoardVantage?
– How is BoardVantage affected by the financial crisis?

What Will the Future Bring for the SEC?

With the US Chamber of Commerce the latest in recommending changes to the SEC (see the other ideas in our “Regulatory Reform” Practice Area), it’s interesting to see what members thought during last week’s poll on what they think should happen with the SEC. Here are the results:

moar funny pictures

– Broc Romanek