On December 22, 2020, the Securities and Exchange Commission proposed to amend Rule 144 to change the holding period determination for securities acquired upon the conversion or exchange of certain market-adjustable securities for unlisted companies so that the holding period would not begin until the conversion or exchange.  The proposal also includes several other amendments relating to Form 144, including:

• Requiring electronic filing of Form 144 for securities of issuers subject to Exchange Act reporting;
• Eliminating the requirement to file a Form 144 for securities of issuers that are not subject to Exchange Act reporting; and
• Amending the filing deadline for Form 144 to coincide with the Form 4 filing deadline.