Mar. 18, 2022
To whom it may concern, I am a retail investor. Retail Investors who engage in insider trading get the book thrown at them by the SEC and prosecutors, but since 2000, a loophole in the law (SEC Rule 10b5-1) has allowed corporate executives essentially to avoid insider trading liability if their transactions are conducted pursuant to pre-arranged trading plans. Unfortunately, the lack of transparency and other executive-friendly provisions surrounding these plans have enabled insiders to engage in de facto insider trading by creating, changing, and canceling the plans virtually at will. The SEC’s proposal is intended to address these deficiencies by significantly increasing the transparency surrounding companies’ adoption and use of these plans and by tightening their requirements. We cannot allow executives to and other company insiders get away with insider trading. Thank you. Sincerely, James Fox