Perhaps someone should submit the following request to the SEC with respect to its Rule 10b5-1 amendment: “Chairman Gensler – we note your definition of the term ‘non-Rule 10b5-1 trading arrangement.’ Please provide a description of the trading arrangements that would be included in, and those that would be excluded from, that definition. It would be particularly helpful if the SEC provided that guidance soon, given the timing within which identification and disclosures of those plans and ‘trading arrangements’ must be made.”
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