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| SEC Proposes Disclosure Rule for Hedging Transactions by Directors, Officers and Employees (PDF) McDermott Will & Emery  Feb. 24, 2015 "The proposed rule implements Section 955 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, and covers a much broader range of transactions than hedging policies adopted at most public companies. The proposed rule would not require a public company to prohibit hedging type transactions. It is appropriate for issuers at this time to consider the extent to which the scope of their existing hedging policies differs from the proposed rule." |
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