Current-law scope and cautions
- Article 44 short-swing disgorgement applies to covered directors, supervisors, senior officers and qualifying shareholders for buy/sell or sell/buy within six months, subject to statutory exceptions.
- Trading while in possession of inside information is a separate prohibition and is not cured by being outside a blackout window.
- Blackout/pre-disclosure periods are issuer/exchange-rule specific and can change; do not hard-code one universal quarterly/annual number.
Use: This is a screening/estimation tool, not a legal opinion. Confirm the latest primary authority, regulator practice, local rules and transaction documents before acting.
