Our recently published report, Rule 10b5-1 Trading Plan Guidelines: A Survey of the SV150, provides an in-depth analysis of the Rule 10b5-1 trading plan guidelines of 75 companies in the Lonergan SV150.  The report examines several key elements of these guidelines including cooling-off periods, minimum terms and maximum terms, trading outside of the trading plan (during the term of the plan), early termination limitations, and mandatory use of trading plans. Some of the highlights of our analysis include:

• A majority (53 percent) of guidelines adhere to the Rule 10b5-1 minimum cooling-off periods, but some apply longer cooling-off periods to additional personnel or impose longer durations than the minimum required in the rule.
• A significant minority (44 percent) of guidelines impose a minimum term, a maximum term, or both, with minimum terms ranging from three months to one year, and maximum terms ranging from one to three years.
• Nearly one-third (32 percent) of guidelines prohibit trading in company securities during the term of a trading plan outside of the trading plan, with some providing for limited exceptions such as dispositions of gifts.
• Many of the guidelines impose restrictions on early termination of trading plans including, for example, requiring notice or prior approval, only allowing early termination during an open trading window, or only allowing early termination when the insider is not aware of material nonpublic information.
• Only a small percentage of companies (11 percent) require company insiders to transact in company securities through trading plans, generally limited to directors, Section 16 officers, and, in some cases, other management or designated personnel.