From: Kurt Vile <vile@apdg.com>
Date: Tue, 4 Jun 1996 07:57:34 +0800
To: tcmay@got.net (Timothy C. May)
Subject: Re: "Insider Non-Trading" (Re: Insider Trading and InsideInformation)
In-Reply-To: <add7aa1b010210045ad9@[205.199.118.202]>
Message-ID: <9606031802.AA12382@smile.apdg.com>
MIME-Version: 1.0
Content-Type: text/plain




tcmay@mail.got.net  wrote:

>The SEC tumbled to this some time ago, and now demands that all
>those who are insiders, or who are married to insiders, or who are
>golfing buddies of insiders register their trading intentions 90
>days in advance of any transaction. (This will increase to 120 days 
>in 1997, and 180 days the following year.)

Those intentions in all likelyhood will not be binding...When I  
used to work for Swiss Bank Corp, the SEC demanded that any person  
who was privy to trading information (basically everyone) had to  
file for approval before making a transaction.  This approval was  
non-binding. I don't think the SEC has the power to mandate that a  
entity commit to a trade 180 days before the trade is suppose to  
happen, after all the instrument the entity is registering their  
intent to make a trasaction in; could have something horrible happen  
to it within 180 days (apple could blow up their headquarters for  
example)

The SEC may however have the power to request a reason for your  
decision not to make the transaction.  Which seems like it would be  
alot of work, since their are tons of and tons of approvals that get  
made.  (I know alot of people who would make a request to trade  
something, not do a trade, but have another request become active  
when the original request expired (they give you a 2 week window or  
so))

--Kurt