Securities Client Memorandum: Rule 10b5-1 and The New "Safe Harbor" for Trading by Insiders of Company Securities
11/15/2000
This memorandum provides guidance concerning the scope of the Rule 10b4-1 and its implications with respect to a company's policies on trades of company securities by Insiders and with respect to securities transactions entered into by Insiders. In addition, attached to this memorandum Annex A, a sample Trading Plan for the sale of company securities by Insiders; Annex B, a sample Memorandum to company officers and directors regarding Rule 10b5-1 and Trading Plans; and Annex C, a sample set of instructions for repurchases of company securities by the company.
