There could be indirect harm to specific shareholders (but not to shareholders in the aggregate) if they make a bad purchase or sale decision based on the bullish but undefined signal an insider is sending via the exercise-and-hold transaction. Regardless of the legalities, it seems contrary to the spirit of insider-trading regs to allow any insider transactions while an insider is in possession of material nonpublic information.
“The efficient-market hypothesis may be the foremost piece of B.S. ever promulgated in any area of human knowledge!”