Survey Results: More on Regulation FD Practices

We conducted a survey four years ago on Regulation FD practices. Since we continue to get so many inquiries on this topic, the survey below asks the same questions to gauge changes in this area:

1. Our company posts information on its corporate website and takes the position that this is sufficient to satisfy Reg FD: (Total responses: n=54)
(select only one)

n=3 (5.56%) Yes, our company takes this position for anything posted on its corporate website
n=9 (16.67%) It depends, our company takes this position for certain items posted on its corporate website (but not all)
n=42 (77.78%) No, our company does not yet take this position

2. Our company has a written policy addressing Reg FD practices: (Total responses: n=55)
(select only one)
n=5 (9.09%) Yes, and it is publicly available on our website
n=38 (69.09%) Yes, but it is not publicly available on our website
n=1 (1.82%) No, but we are in the process of drafting such a policy
n=11 (20.00%) No, and we do not intend to adopt such a policy in the near future

3. Regarding reaffirmation of earning announcements, our company uses one of the following rules of thumb regarding private reaffirmations: (Total responses: n=50)
(select only one)
n=38 (76.00%) We do not allow private reaffirmation
n=3 (6.00%) Rule of thumb allowing for private reaffirmations of one week or less
n=3 (6.00%) Rule of thumb allowing for private reaffirmations of one to two weeks
n=2 (4.00%) Rule of thumb allowing for private reaffirmations of two to three weeks
n=4 (8.00%) We permit private reaffirmations - but never use a rule of thumb, instead we require confirmation of no material change with CEO, GC, etc.

4. At our company, our CEO and other senior managers: (Total responses: n=54)
(select all that apply, may total more than 100%)
n=2 (3.70%) Are not permitted to meet privately with analysts
n=25 (46.30%) Are only permitted to meet privately with analysts so long as someone else accompanies them (such as general counsel or IR officer)
n=13 (24.07%) Are permitted to meet privately with analysts after briefing by IR officer, general counsel, etc.
n=18 (33.33%) Are only permitted to meet privately with analysts during certain designated times
n=20 (37.04%) Are not permitted to talk about certain topics