Exhibit 19 insider trading policies
Company insider trading policies filed as Exhibit 19 to the 10-K under Item 408(b) of Regulation S-K, searchable in full text.
curl -H "Authorization: Bearer $SECFEED_KEY" \ "https://secfeedapi.com/v1/filings?query=formType:%2210-K%22%20AND%20filedAt:%5B2025-01-01%20TO%202025-12-31%5D&size=2"
import os, requests
r = requests.get(
"https://secfeedapi.com/v1/filings",
params={'query': 'formType:"10-K" AND filedAt:[2025-01-01 TO 2025-12-31]', 'size': '2'},
headers={"Authorization": f"Bearer {os.environ['SECFEED_KEY']}"},
)
print(r.json())What is Ex 19?
Since the SEC's 2022 Rule 10b5-1 amendments, companies must disclose whether they have adopted insider trading policies and procedures for directors, officers and employees (Item 408(b) of Regulation S-K), and file the policy itself as Exhibit 19 to the annual report.
The requirement applies to fiscal years beginning on or after April 1, 2023, so the first wave of Exhibit 19 filings arrived with 10-Ks filed in 2025. The policies describe blackout windows, preclearance, hedging and pledging restrictions and 10b5-1 plan rules, which makes them useful for compliance benchmarking. The counts on this page cover all 10-K filings.
Domestic companies filing a 10-K. Foreign private issuers file their policy with the 20-F under Item 16J.
With the annual report on Form 10-K, starting with fiscal years beginning on or after April 1, 2023 (smaller reporting companies included).
What is inside
| Section | Contents |
|---|---|
| Covered persons | Directors, officers, employees and often family members and controlled entities. |
| Blackout periods | Quarterly trading windows and event specific blackouts. |
| Preclearance | Who must clear trades in advance and with whom. |
| Hedging and pledging | Prohibitions or limits on hedging and pledging company stock. |
| Rule 10b5-1 plans | Rules for adopting, modifying and terminating trading plans, including cooling off periods. |
Get Ex 19 data with SecFeed
Search the filings with formType:"10-K" AND filedAt:[2025-01-01 TO 2025-12-31], read any document as text or PDF, and use these APIs for structured data:
Search every word of every EDGAR filing and exhibit since 2001. Exact phrases, form type, CIK and date filters, results as JSON.
Download Filings & ExhibitsList every file in an SEC filing and download any document, exhibit, XBRL file or image from the EDGAR archive with one authenticated call.
Form 3/4/5Insider Trading APIEvery insider transaction from SEC Forms 3, 4 and 5 since 2006 as clean JSON: insider, role, transaction code, shares, price, value and 10b5-1 flag.
Use cases
- Benchmark blackout window and preclearance practices across an industry
- Check whether a company prohibits hedging or pledging
- Pair the policy with Form 4 filings to study trading inside windows
Related forms
Every Form 10-K annual report filed on EDGAR since 1993, searchable by company, date and text, with sections and XBRL financials as JSON.
Form 4Insider tradingEvery Form 4 statement of changes in beneficial ownership since 2003, parsed into transactions with insider, role, code, shares and price.
DEF 14AProxy statementsEvery DEF 14A definitive proxy statement since 1994: executive pay, board members, audit fees, pay versus performance and ballot proposals.
FAQ
When did companies start filing Exhibit 19?
With 10-Ks for fiscal years beginning on or after April 1, 2023, which for calendar year companies means 10-Ks filed in early 2025.
Where does a company say it has no insider trading policy?
In the 10-K or proxy disclosure under Item 408(b), which must explain why if no policy has been adopted.
Every Ex 19 filing, one API call away
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