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CIP for Publicly Traded Company

Does a publicly traded company need to have a CIP filled out for the company and the signers?

by Randy Carey:

A publicly traded company is exempt from CIP, anything you do is totally self imposed by your board approved CIP policy.


by Jim Bedsole:

Actually, the regulation indicates that publicly traded companies whose common stock is traded on the NYSE, AMEX, or NASDAQ-National Market exchanges are exempt as well as subsidiaries of such companies. In addition, any company that is an issuer of a class of securities registered under Section 12 of the Securities Exchange Act of 1934 or that is required to file reports under Section 15(d) of that Act is also exempt. But I would presume that there could be publicly traded companies that do not meet either of these standards. Such a company would likely be a smaller company whose stock might be traded as an OTC stock. For those entities, BO and CIP would apply for at least a control person as well as for any owner of more than 25% of the entity.

First published on 12/01/2019

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