"Since the Dodd-Frank requirement is a disclosure rule and not a listing exchange requirement, companies are not required to have in place any particular hedging policy. Instead, they must simply disclose the existence of any policy, its terms and who is covered. Companies adopting anti-hedging policies must decide whether to cover all employees or whether there are some circumstances in which hedging is permissible. Companies also will need to review existing policies to make sure they are worded broadly enough to cover all potential hedging transactions, assuming that is the policy goal."  MORE >>