Cal-Bay International Inc (CBYI)

[The Real Titan]

Okay guys... please don't attack me, just wanted to get the expert opinions. I found this on another forum and wanted to see if it held any truth.

There may be a loophole, allowing companies to sell before the 6 month period, so I thought it was worth posting.

"... 1. Trading in Securities on a Short Term Basis. Any Company stock purchased in the open market should be held for a minimum of six months and ideally longer. Note that the SEC’s short-swing profit rule already penalizes officers and directors (Section 16(b) individuals) who profit from the sale of any Company stock within six months of a purchase. If an officer or director wishes to sell Company stock purchased in the open market and which has been owned less than six months, or purchase Company stock within six months of a sale, written pre-clearance from the General Counsel or the CFO must be obtained prior to the transaction.

2. Any Trade by an Officer or Director. Any transaction in Company stock by any officer or director must be cleared by the General Counsel or the CFO. This means that you must get authorization before you buy, sell, exercise options, give stock as a gift – any transaction. The only exception is if you have properly entered into a "planned sale program" (i.e., a 10b5-1 Trading Plan), the form of which has been approved by the Company. In addition, as of August 29, 2002, all trades by officers and directors must be filed with the SEC within 2 business days after the trade is done. Officers and directors must report trades to the Company within 24 hours after completion so that the Company has time to complete the appropriate filings...." http://www.phoenix.com/NR/rdonlyres/...ing_Policy.pdf