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Steady_T

05/26/26 2:23 PM

#518807 RE: sab63090 #518805

Section 16 "Insiders": For trading and reporting rules under Section 16, the SEC defines an officer more narrowly in Rule 16a-1(f). Under this rule, a vice president is only an officer if they are in charge of a principal business unit, division, or function (e.g., sales, administration, or finance) or perform similar policy-making duties.In short, a vice president holding a mere ceremonial title without substantive executive duties is generally not considered an officer by the SEC, whereas one running a major division or making company policies is.3 sitesWho are your Section 16 officers? - Williams MullenSep 25, 2013 — For the most part, determining your Section 16 officers is a fairly routine matter, and the SEC respects and rarely challenges the...Williams MullenSection 16 Officers: What Every Public Company Executive ...May 13, 2025 — What Is a Section 16 Officer? Section 16 of the Securities Exchange Act of 1934 establishes reporting requirements and trading res...Candor.co240.3b — Definitions - Deloitte Accounting Research Tool
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Doc328

05/26/26 2:26 PM

#518808 RE: sab63090 #518805

Are they 'key enough' to need an 8K if they leave --- their options have never been reported on a form 3 or 4 and their hiring did not trigger an 8K (just a PR which is always optional)
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BIOChecker4

05/26/26 5:15 PM

#518818 RE: sab63090 #518805

8-K filings are only required for officers and directors of a public company. None of these departing folks were officers or directors.