Subject: Request for Possible Waiver Regarding Trading Policy
Hi everyone,
I’m reaching out to inquire about the possibility of obtaining a waiver from my bank concerning its trading policy. Currently, the bank has a standard requirement that all trades must receive prior approval.
The challenge we face is that a significant portion of our household income is linked to my husband’s Restricted Stock Units (RSUs) and stock options from his employer, a publicly traded company. He can only trade outside of his company’s blackout periods and always secures written approval whenever he exercises his RSUs or options.
The timing can be quite problematic, as getting both his company’s and my bank’s approvals on the same day is often difficult.
Do you think there’s a chance my bank would consider granting a waiver for his transactions, provided that I can certify that they comply with the insider trading policies of his company?
Are there any realistic adjustments or accommodations I might request from my compliance team in this situation?
Thank you in advance for your insights!
One response
It’s understandable that navigating trading policies can be challenging, especially in situations where income is tied to RSUs and stock options. Here are a few suggestions you might consider when approaching your compliance group:
Explain the Situation: Clearly outline the unique challenges you’re facing with timing approvals due to the dual requirements from both your husband’s employer and your own. Emphasizing the reliance on these stock sales for household income might help illustrate the urgency.
Propose a Solution: Suggest that a waiver or streamlined process could be beneficial. For instance, you might propose that your trades be pre-approved or that you receive a broader type of approval that covers multiple transactions, provided they comply with the insider trading policies of your husband’s company.
Offer Certifications: You can propose that you certify that all trades will comply with his company’s insider trading policies, perhaps even requesting to maintain documentation of these transactions that can be reviewed if needed.
Speak to Precedents: If you know of any similar accommodations made for other employees or have heard of similar cases, mention those. This might support your case by showing that your request is reasonable within the context of existing practices.
Request a Meeting: If possible, request a one-on-one meeting with a member of the compliance team to discuss your situation in detail. Personal interaction may allow for a clearer discussion and demonstrate your willingness to ensure compliance with all policies.
Ultimately, while there is no guarantee that your request will be granted, presenting a well thought-out proposal that considers both your needs and the company’s policies might increase your chances of finding a feasible solution. Good luck!