On August 26, 2021, the Investor as Owner Subcommittee of the Securities and Exchange Commission’s Investor Advisory Committee issued its draft recommendation on proposed changes to the “affirmative defense” and disclosure and reporting requirements for Rule 10b5-1 trading plans. The Investor Advisory Committee is widely expected to approve recommendations based on this draft at its meeting on September 9, 2021, after which we expect that the SEC will propose rules in this area.