Confirmed.
Question
From: Musick, Vesselina <vmusick@ftc.gov>
Sent: Monday, June 5, 2023 3:10:16 PM (UTC-05:00) Eastern Time (US & Canada)
To: [Redacted]
Cc: HSRHelp <HSRHelp@ftc.gov>
Subject: RE: 801.30 as applied to employee-based compensation awards
Confirmed.
From: [Redacted]
Sent: Monday, June 5, 2023 10:03:23 AM (UTC-05:00) Eastern Time (US & Canada)
To: HSRHelp <HSRHelp@ftc.gov>
Subject: 801.30 as applied to employee-based compensation awards
Hello PNO,
I just want to confirm that you are still of the view that acquisitions of voting securities through stock-based compensation awards to company employees, officers or directors, such as the vesting of RSUs/PSAs, the exercise of stock options, or other executive compensation arrangements, should be filed as conversions under Rule 801.30, as indicated in PNPM opinion 217.