Nova 401(k) Associates
Nicholas Pension Consultants
Compensation Strategies Group, Ltd.
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|Dodd-Frank Mandated Disclosure of Hedging Policies: The SEC's Proposed Rule (PDF)|
Wilkins Finston Friedman Law Group LLP
Feb. 22, 2015
"The types of hedging transactions covered by the disclosure rules include not only prepaid variable forward contracts, equity swaps, collars, and exchange funds, but also all transactions that establish 'downside price protection,' such as short sales. If a company permits certain types of hedging transactions, the category of permitted transactions must be described. If all transactions are prohibited, or all are permitted, then a listing of categories covered need not be disclosed. If a company permits some of its employees to engage in hedging transactions, then it must specify those who are permitted and those who are not (i.e., if the policy prohibits hedging by executive officers and directors, but not by other employees)."
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