Tuesday, April 19, 2022 10:47:55 PM
3. Volume: The aggregate purchases on any given day must not exceed 25% of the purchased security’s ADTV. “Block”8 trades typically will be included in computing a security’s ADTV. However, once per week, “in lieu of purchasing under the 25 percent of ADTV limit for that day,”9 a company or its affiliated purchasers may make one block trade of its shares without regard to the volume limit, provided that it does not make any other Rule 10b-18 purchases on the same day. Purchases made pursuant to this block trade exception will not be included in computing a security’s ADTV for purposes of Rule 10b-18 volume limits;
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