SEC Proposes Major Rule Changes on Trading Plans and Corporate Buybacks

December 28, 2021

On December 15, 2021, the SEC issued for public comment two separate proposals that will, if adopted, significantly affect how corporate directors, officers and employees trade securities of their companies and how companies repurchase their own shares.

This memorandum walks through the two proposals in turn and concludes with some general takeaways and possible issues for comment.