Rule 701 disclosure requirements when sales exceed $5M

[Guest hapa123]

Under Rule 701, if the aggregate sale price of securities sold in reliance on the Rule exceeds $5,000,000 in a 12-month period, the issuer becomes subject to certain disclosure requirements. One of these requirements is that the issuer deliver to the investors financial statements "no more than 180 days before the sale of the securities" in reliance on Rule 701.

With respect to a stock option granted in reliance on Rule 701 by a company subject to the above-mentioned disclosure requirements, when does the 180 day disclosure reqt for financial statements start? 180 days before the option exercise date? Or 180 days before the option grant date? In other words, which is the "sale" triggering the 180 day reqt -- the grant or the exercise of the option?