ARTICLE
11 January 2022

SIFMA Requests Comment Period Extension For Proposed Insider Trading Amendments

CW
Cadwalader, Wickersham & Taft LLP

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SIFMA requested that the SEC extend the comment period for proposed rule changes to various provisions covering affirmative defenses and disclosures related to insider trading.
United States Corporate/Commercial Law

SIFMA requested that the SEC extend the comment period for proposed rule changes to various provisions covering affirmative defenses and disclosures related to insider trading.

In its letter, SIFMA requested that the SEC extend a 45-day comment submission period to a 90-day period for proposed rule changes to SEA Rule 10b5-1 ("Trading on the Basis of Material Nonpublic Information in Insider Trading Cases"). The proposed amendments would include additional disclosures and conditions for affirmative defenses in insider trading cases (see prior coverage). SIFMA stated that additional time is needed to analyze the proposed rules and their impact on a broad range of market participants. In addition, SIFMA noted that multiple rule proposals are currently open for comment affecting the association's ability to fully consider the proposal and its potential effects within the current 45-day window.

Primary Sources

  1. SIFMA Press Release: Insider Trading Plans Proposed Rules
  2. SIFMA Comment Letter: File No. S7-20-21; Rule 10b5-1 and Insider Trading

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