On September 21, 2022, the SEC found that Cheetah Mobile Inc.’s Chief Executive Officer and former President had committed insider trading on trades executed through their joint 10b5-1 plan. Notably, as part of a cease-and-desist order, the two agreed to complete various undertakings. As this memorandum explores, some of those undertakings parallel the SEC’s proposed amendments to Rule 10b5-1, perhaps signaling the impending changes to Rule 10b5-1 and how the industry might prepare to adjust.