A Survey of the SV150

Wilson Sonsini is pleased to present Insider Trading Policies: A Survey of the SV150, which analyzes the insider trading policies of Silicon Valley’s largest public companies.

This report summarizes the results of our review of the insider trading policies filed by 145 companies in the Lonergan SV150, which ranks the top 150 companies with headquarters in the Silicon Valley by annual sales. [1] For more information on the methodology used to prepare the Lonergan SV150, please visit the Lonergan Partners website. Please see the Appendix for a list of the SV150 companies.

In December 2022, the U.S. Securities and Exchange Commission (SEC) adopted final rules that require, among other things, public companies to file their insider trading policies and procedures as an exhibit to their annual report (2022 rules). [2] This report examines certain key elements in these insider trading policies such as:

• persons subject to the insider trading policy;
• quarterly blackout periods (or trading windows) [3] and timing;
• pre-clearance requirements;
• gifts; and
• restricted activities including hedging, pledging, and margin accounts.

We would like to thank the team that conducted the research and provided editorial input for this report, including partners Richard Blake, Tamara Brightwell, Shannon Delahaye, Lauren Lichtblau, Jose Macias, Lisa Stimmell, and practice support lawyer Courtney Mathes.

(more…)