"Section 14(j) of the Exchange Act covers hedging transactions conducted by any employee or member of the board of directors or any of their designees. The SEC believes the term 'employee' should be interpreted to include everyone employed by an issuer, including its officers. According to the SEC it is just as relevant for shareholders to know if officers are allowed to effectively avoid restrictions on long-term compensation as it is for directors and other employees of the company.... The SEC does not propose to exempt smaller reporting companies or emerging growth companies from Item 407(i) disclosure."