SEC Hedging Policy Disclosure Rules Take Effect

The SEC’s previously adopted hedging policy disclosure rule, which requires companies to disclose in their proxy statements for director elections any practices or policies regarding the ability of employees, officers or directors to engage in certain hedging transactions with respect to the company’s securities, took effect on July 1, 2019. If a company does not have any such practices or policies, it must disclose that fact or state that hedging transactions are generally permitted. The full text of the final rule is available here.