12/17/2002: PSCA Comments on SEC's Proposed Rules for Insider Trading During Blackout Periods (PDF) (Profit Sharing/401(k) Council of America)3 pages. Excerpt: "The proposed definition of securities acquired in connection with service or employment includes securities ... that he or she must hold to meet an issuer's minimum ownership requirements for directors ... These securities could be securities that were acquired years before becoming a director. PSCA believes that treating securities that were purchased prior to becoming a director as acquired in connection with service as a director is inconsistent the Act's intent ..."
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