July 11, 2012
Survey Results: HSR & Executives’ Acquisitions from Equity Compensation Plans
We have posted the survey results regarding typical practices for company executives and HSR filing fees, repeated below:
1. Does your company require executives to comply with HSR filing requirements upon acquiring company shares:
– Yes, and they have been for a while – 39%
– Yes, but only recently because of this enforcement action – 16%
– No – 45%
2. If the answer to #1 above is “yes,” who pays the HSR filing fee:
– Executive with no reimbursement by the company – 40%
– Executive with full reimbursement by the company – 20%
– Executive with partial reimbursement by the company – 0%
– Company – 40%
3. If the executive pays HSR filing fee but is partially reimbursed by the company, in what manner is the reimbursement:
– Specified percentage – 0%
– Specified dollar amount – 50%
– Specified Formula – 50%
Please take a moment to participate in this “Quick Survey on Rule 10b-18 & Buybacks.”