Survey Results: Insider Trading Policies: Pledges & Margin Accounts


1. Does your company's insider trading policy prohibit insiders from pledging their company shares? (Total responses: n=53)
(select only one)
n=20 (37.74%) Yes
n=33 (62.26%) No

2. If your company's insider trading policy does not prohibit pledges, does your company: (Total responses: n=27)
(select all that apply, may total more than 100%)
n=15 (55.56%) Discourage or advise against pledges
n=18 (66.67%) Require preclearance for pledges
n=5 (18.52%) Include criteria that must be met for pledges (e.g., financial wherewithal, limited to a specified percentage of holdings)

3. If your company's insider trading policy requires preapproval or satisfaction of certain criteria for pledges, who makes that determination? (Total responses: n=24)
(select all that apply, may total more than 100%)
n=0 (0.00%) CEO
n=1 (4.17%) CFO
n=19 (79.17%) GC
n=1 (4.17%) Board Committee
n=4 (16.67%) Other

4. Does your company's insider trading policy prohibit insiders from using margin accounts with their company shares? (Total responses: n=52)
(select only one)
n=21 (40.38%) Yes
n=31 (59.62%) No

5. If your company's insider trading policy does not prohibit margin accounts, does your company: (Total responses: n=23)
(select all that apply, may total more than 100%)
n=15 (65.22%) Discourage or advise against margin accounts
n=13 (56.52%) Require preclearance for margin accounts
n=4 (17.39%) Include criteria that must be met for margin accounts

6. If your company's insider trading policy requires preapproval or satisfaction of certain criteria for margin accounts, who makes that determination: (Total responses: n=17)
(select all that apply, may total more than 100%)
n=0 (0.00%) CEO
n=2 (11.76%) CFO
n=15 (88.24%) GC
n=0 (0.00%) Board Committee
n=2 (11.76%) Other

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