Close the insider-trading window before earnings
Reinforce SEC trading-window order from public-company training. Pre-existing 10b5-1 trades already in place are the exception; ad-hoc trades are not pre-cleared after the fact.
- Identify the blackout start from the financial calendar.
- Notify insiders.
- Freeze the preclearance queue.
- Halt new 10b5-1 adoptions inside the quiet period as policy requires.
- Allow only trades under a pre-existing 10b5-1 plan that meets the exception.
- Review attempted trades and deny those without an exception.
- Reopen only after the earnings release and the taught cooling interval.
- Do not approve a trade because the insider already decided last month.