SEBI's Comprehensive FAQs on Insider Trading Regulations
SEBI recently released comprehensive FAQs in respect of SEBI (Prohibition of Insider Trading) Regulations, 2015 in furtherance to its earlier FAQ on April 29, 2021, which consolidated all the FAQs and guidance notes issued earlier. With a view to provide more clarity and ease of reference, these FAQs are categorized subject-wise under various headings, namely, trading, structured digital database, disclosures, pledge, trading plan, pre-clearance, trading window closure, contra-trade, etc.
Some of the issues addressed include Whether creation of pledge, invocation of pledge and revocation of pledge can be deemed as trading?, Whether trading on the basis of UPSI is prohibited even for persons not falling under the definition of ‘Designated Persons' under the PIT Regulations?, What information should a listed company maintain in its structured digital database under Regulation 3(5), in case the designated person is a fiduciary or intermediary?, Does list of UPSI as prepared by the company in-house needs to be disseminated to public at large?, Whether transfer of shares from one Demat account to another Demat account of the same person will trigger the disclosure requirements?, Whether requirement of pre-clearance is applicable for exercise of employee stock options?, And such other important issues.
