Creating a comprehensive insider trading policy requires extensive research across SEC regulations, federal securities laws, and industry best practices. Corporate counsel spend hours searching for current compliance requirements, verifying citations from SEC.gov and the Federal Register, and ensuring all necessary sections meet legal standards—all while keeping pace with regulatory updates.
Creating comprehensive insider trading policies requires deep securities law expertise, constant monitoring of SEC rule changes, and extensive customization to company-specific circumstances. Manual drafting takes 12+ hours and risks missing critical compliance requirements like the 2022 Rule 10b5-1 amendments or industry-specific trading risks.
CaseMark generates fully customized, SEC-compliant insider trading policies incorporating current regulations, Rule 10b5-1 safe harbors, blackout procedures, and enforcement frameworks. The AI analyzes your corporate documents to tailor definitions, examples, and procedures to your company's structure, listing status, and industry.
This workflow is applicable across multiple practice areas and use cases
Securities lawyers need compliant insider trading policies for public company clients to meet SEC regulatory requirements and Rule 10b5-1 compliance standards.
This workflow directly addresses core securities law compliance requirements including SEC rules, material nonpublic information handling, and Section 16 reporting - all central to securities and capital markets practice.
Corporate finance attorneys advising on IPOs, secondary offerings, and capital raises need insider trading policies to ensure compliance during securities transactions and protect against trading violations.
Companies engaging in corporate finance activities must have robust insider trading policies in place, particularly during capital raising events when material nonpublic information is prevalent.
M&A attorneys need to ensure target companies and acquirers have compliant insider trading policies in place during due diligence and transaction execution when material nonpublic information is exchanged.
M&A transactions involve extensive sharing of material nonpublic information among insiders, making insider trading policies critical for compliance and risk management during deal processes.
VC and PE firms advising portfolio companies preparing for IPO or already public need insider trading policies for board members, investors, and executives with access to material nonpublic information.
Private equity and venture capital professionals often serve on boards and have access to material nonpublic information, requiring compliant policies especially as portfolio companies approach public markets.
Financial services firms and broker-dealers need insider trading policies to comply with securities regulations and protect against trading violations by employees with access to client information.
Financial services institutions are subject to securities law compliance requirements and must implement insider trading policies to manage regulatory risk and protect against employee violations.
Yes, CaseMark incorporates all 2022 SEC amendments including the enhanced cooling-off periods (90 days for directors and officers, 30 days for others), limitations on multiple overlapping trading plans, and required good faith certifications at plan adoption. The policy reflects current SEC guidance on trading plan requirements and safe harbor conditions.
Absolutely. While the policy is designed for public companies subject to SEC reporting, CaseMark can adapt the framework for private companies by adjusting Section 16 reporting requirements, modifying blackout period triggers, and focusing on common law fiduciary duties rather than SEC enforcement. The core prohibitions on trading with material nonpublic information apply regardless of public/private status.
The policy includes comprehensive provisions prohibiting trades in any company's securities when employees possess material nonpublic information obtained through their position. This commonly arises in M&A situations, partnerships, or supplier/customer relationships. CaseMark provides specific examples and guidance on identifying when information about third-party companies triggers trading restrictions.
The policy establishes mandatory initial and annual training programs for all covered persons, with enhanced training for individuals with regular access to material information. It includes annual written certifications confirming policy receipt, understanding, and compliance, plus acknowledgment forms for new hires and directors. CaseMark generates the certification language and tracking procedures.
CaseMark creates quarterly blackout periods typically beginning two weeks before quarter-end and ending two trading days after earnings release, plus event-specific blackouts for material developments. Pre-clearance procedures require Section 16 officers and directors to obtain written approval before any trade, with approval valid for only 2-3 trading days. The policy designates the compliance officer and establishes request/approval workflows.