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Re: concapk post# 197073

Monday, 06/17/2019 12:26:53 PM

Monday, June 17, 2019 12:26:53 PM

Post# of 427373

Blackout period extended to late 2019, past expected catalysts....includes all types of securities....



Source is where or who? If you have an email from Elisabeth, post it - how do we know this isn't just another rumor without confirmation?


Prior pre-clearances are suspended (principals cannot exercise options )



You're saying 10b5-1 plans are also suspended until late 2019? I don't think blackout periods apply to those plans. This lawyer says they're not, only changes to those plans should be barred during them, but it's not a requirement:

https://www.parkerpoe.com/news/2012/07/shedding-light-on-blackout-periods

10b5-1 Plans. Rule 10b5-1 plans allow insiders to make trades pursuant to a preset schedule set forth in the plans and, accordingly, provide them with an affirmative defense to a claim of insider trading. Trades under Rule 10b5-1 plans are not subject to blackout periods. The SEC has noted that insiders may be misusing Rule 10b5-1 plans by entering into, amending and cancelling the plans on short notice, thereby effectively trading on inside information. Consider whether your insider trading policy should prohibit the entrance into or amendment or cancellation of a Rule 10b5-1 plan during a blackout period. If it does not, be wary of any such change to a 10b5-1 plan during a blackout since the insider is prohibited from having material non-public information at the time of any such change.


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