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.

  1. Identify the blackout start from the financial calendar.
  2. Notify insiders.
  3. Freeze the preclearance queue.
  4. Halt new 10b5-1 adoptions inside the quiet period as policy requires.
  5. Allow only trades under a pre-existing 10b5-1 plan that meets the exception.
  6. Review attempted trades and deny those without an exception.
  7. Reopen only after the earnings release and the taught cooling interval.
  8. Do not approve a trade because the insider already decided last month.