You are talking about two different things it seems There are the rule 144 restrictions which are pretty much set in stone by the SEC,and there are company restirctions which of course can be changed. However there are huge difficulties placing a sub penny stock+ DTC chill + insider stock with brokerage firms these days.And they have to report purchases and sales on Form 4.
However I guess what is the point ? That CFO will find way to compensate himself is pretty normal.That people in business often will find all sorts of justifications to defend their own pay, especially when they control the voting shares, wouldnt be a surprise. What would you expect to be paid to take on risk and challenge this CFO has for example ?