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Determine Who Must File a Form 5
- Request Transaction and Ownership Information in D&O Questionnaire
- Review Company Records of Plan Transactions
- Attach "No Filing Due" Certificate to D&O Questionnaire
- Obtain Information or Certificate From Officers and Directors Who Left the Company During the Fiscal Year
Identify Reportable Transactions
- Determine Whether Form 5 is Required
- Determine Whether Stock Purchase Plan Qualifies as Broad-Based
- Update Holdings under DRIPs and Tax‑Conditioned Plans if Otherwise Reporting a Table I Transaction
- Identify Any Discretionary Transactions
- Do Not Include Post‑Year‑End Transactions in Form 5
Obtain Signed Forms 5 or Powers of Attorney
File Forms 5 by 10:00 p.m. on February 14th
Post Section 16 Reports on Issuer's Website if Website Not Linked to Other Source
Prepare Any Proxy Statement/Form 10‑K Disclosure Required under Item 405
- Identify and Disclose Delinquent Transactions
- Disclose Failure to Obtain "No Filing Due" Certificate Unless Filing Compliance Known
- Include Disclosures under Separate Caption
Have Board of Directors Approve List of Section 16 Officers
Review Eligibility of Compensation Committee Members as Non‑Employee Directors
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