On December 15, 2021, the Securities and Exchange Commission unanimously proposed amendments that would (1) implement mandatory cooling-off periods for Rule 10b5-1 trading plans, (2) enhance the affirmative defense requirements under Rule 10b5-1 (including by adding a written certification requirement and providing that the affirmative defense would not be available for overlapping plans or to more than one single-trade Rule 10b5-1 trading plan during any consecutive 12-month period) and (3) impose new disclosure requirements regarding insider trading plans. These amendments also would impose new disclosure requirements for grants of equity compensation awards made close in time to disclosure of material non-public information and require reporting gifts of securities by insiders on Form 4.