To our clients and friends:
Item 402(x) of Regulation S-K, promulgated as part of the SEC’s final rule on insider trading arrangements, is effective today. Item 402(x) will require additional narrative disclosure of internal policies and practices governing the timing of stock option grants, as well additional tabular disclosure if stock option grants are made in proximity to the release of material nonpublic information.
Our Alert regarding the requirements and certain changes issuers should consider is available here.