Subject: Request for Waiver on Trading Policy
Hello,
I’m reaching out to inquire about the possibility of obtaining a waiver from my bank regarding its trading policy. Currently, my bank has a standard requirement that requires approval for any trade.
My situation is a bit complex because a significant portion of our household income is linked to my husband’s Restricted Stock Units (RSUs) and stock options from his employer, which is a public company. He can only trade outside of his blackout periods and must obtain internal written approval whenever he exercises his RSUs or options.
The challenge arises with timing; it’s often difficult to secure both his company’s written approval and my bank’s approval to trade on the same day.
Do you think there’s a possibility that my company would consider granting a waiver for his sales in the future, as long as I can certify that these transactions comply with his employer’s insider trading policies?
Are there any realistic accommodations I could discuss with my compliance team in this situation?
Thank you in advance for your help!
One response
It sounds like you’re navigating a complex situation with your bank’s trading policy and your husband’s stock options. While I can’t provide legal or financial advice, I can suggest a few steps you might consider taking:
Communicate with Your Bank: Reach out to your bank’s compliance department directly. Explain your situation in detail, emphasizing the unique nature of your husband’s income sources and the timing challenges you face.
Propose a Solution: When discussing your situation, suggest a potential solution, such as a standing approval for trades related to your husband’s RSUs and options, provided they comply with insider trading policies. This proactive approach can demonstrate your willingness to work within the framework of their policy.
Documentation: Be prepared to provide documentation that supports your request, including any written approvals from your husband’s employer and assurances that all trades would adhere to their insider trading policies.
Flexibility and Understanding: Keep in mind that banks have compliance policies for a reason, often related to regulatory concerns. Express understanding of their position, which might make them more inclined to find a workable solution together with you.
Seek Alternatives: If your bank is unable to accommodate your request, consider asking if there are alternative approaches that would allow for more timely trading while still adhering to their policies.
Consult Legal/Compliance Advisors: If you have access to legal or compliance advisors within your company, discuss your options with them. They may provide insights into how to frame your request or whether similar accommodations have been made for others in the past.
Ultimately, the key is open communication with your bank and being clear about your specific needs while remaining compliant with their trading policies. Best of luck!