In addition to the various changes we know are coming under the Dodd-Frank Act–e.g., CEO to median employee pay ratio, disclosures of hedging policies, expanded clawback requirements, expanded pay-for-performance disclosures, Say-on-Pay (wait, that’s already here)–this week, I blog about a potential change you might not have been aware of: less time to file Forms 3.

Form 3 Deadline
In a little-known provision (at least to me), the Dodd-Frank Act amended Section 16(a) to authorize the SEC to shorten the deadline for filing Forms 3. The amendment isn’t effective until July and then some SEC rulemaking will be necessary to effect the change, but, since the SEC requested the authority to do this, it seems likely that they will follow through on it.

Currently, when someone becomes an insider at a reporting company, a Form 3 must be filed within ten days. Alan Dye, of Section16.net and Hogan Lovells, speculates that the SEC will change the deadline to be more in line that of Form 4–e.g., two business days.

As things stand now, most new officers and directors receive a grant upon assuming their new role that must be reported on Form 4 within two business days anyway, even if the Form 3 is not due for ten days (and, in this circumstance, the SEC encourages insiders to file the Form 3 concurrently with the Form 4). It does seem to me to create a fundamental unbalance in the universe to file a Form 4 before filing a Form 3 for an insider–now, presumably, balance will be restored (at least, that’s what Alan thinks–and my money’s on him–but this is all speculation, we don’t actually know what the new Form 3 deadline will be).

A two-day deadline on filing Forms 3 will make it even more critical to be on top of obtaining EDGAR codes for new insiders.

Thanks to Tami Bohm of Radian Group (and member of the NASPP Executive Advisory Committee) for bringing this development to my attention.

A More Social NASPP
The NASPP is networking socially: you can now follow us on Twitter or like us on Facebook. We’ll be posting announcements whenever we post new content on Naspp.com–it’s a great way to keep up with all the content we have on the website.

Online Fundamentals–Early-Bird Ends February 25
The NASPP’s acclaimed online program, “Stock Plan Fundamentals,” begins on April 14. This multi-webcast course covers the regulatory framework and administrative best practices that apply to stock compensation. It’s a great program for anyone new to the industry or anyone preparing for the CEP exam. Register by February 25 for early-bird savings.

Submit Speaking Proposals for the NASPP Conference by February 28
The NASPP is currently accepting speaking proposals for 19th Annual NASPP Conference.  Submit your proposal by February 28. 

NASPP “To Do” List
We have so much going on here at the NASPP that it can be hard to keep track of it all, so I keep an ongoing “to do” list for you here in my blog. 

• Check out the NASPP’s Facebook and Twitter pages.
• Register for the NASPP online Stock Plan Fundamentals program.
• Submit your speaking proposal for the NASPP Conference.
• Complete the Compliance-O-Meter quiz on Section 16.
• Take the “Question of the Week” challenge.
• Purchase the audio for the 18th Annual NASPP Conference.
• Renew your NASPP membership for 2011 (if you aren’t an NASPP member, join today).
• Attend your local NASPP chapter meetings in Houston, Phoenix, Sacramento, San Fernando Valley, and Silicon Valley. I’ll be at the Silicon Valley meeting and Rachel will be at the Sacramento meeting; we hope to see you there!

– Barbara