Arnold & Porter Discusses SEC Staff Issuance, Revision, and Withdrawal of C&DIs for Rule 10b5-1
On April 25, 2025, the SEC Staff issued two new Compliance and Disclosure Interpretations (C+DIs) with respect to Rule 10b5-1. Under the first (Qu. 120.32), the Staff advised that purchases and sales of issuer securities pursuant to a …