10b5-1 Plans Best Practices Checklist


Summary

This checklist outlines steps to develop and implement a Rule 10b5-1 trading plan that defensibly meets the requirements of Rule 10b5-1 (17 C.F.R. § 240.10b5-1), promulgated under the Securities Exchange Act of 1934, as amended (the Exchange Act). When properly implemented, a 10b5-1 plan enables the execution of trades on behalf of insiders, even when they know material, nonpublic information (MNPI) about the company whose stock is traded, so long as the plan was established when the insider was not in possession of MNPI and the trades were executed pursuant to the plan.