GPS

Guidance - Procedures - Systems

Public Comment

The Certified Equity Professional Institute (CEPI) at Santa Clara University is pleased to announce that both Phase 1 and Phase 2 of the research study have been finalized and include feedback from the public comment periods.

Phase 3: Legal Issues and Changes of Employment Status is open for public comment until September 4, 2007.

The CEPI invites individuals and organizations to send written comments on all matters in this draft. Specifically, the CEPI invites individuals and organizations to comment on the following issues.

• Do the illustrative controls and tests of those controls provide adequate coverage? If not, what additional controls should be included? See controls in Sections 7 and 8 for details.
  
• Are the best practices regarding 10b5-1 plans outlined in Exhibit 15 sufficient and reasonable?
  
• Is additional guidance necessary for any of the topics covered in this publication?

Comments are requested from those who agree with this draft as well as from those who do not. Comments are most helpful if they identify the issues or specific paragraph or group of paragraphs to which they relate and clearly explain the issue or question. Those who disagree with provisions of this draft are asked to describe their suggested alternatives, supported by specific reasoning.

Comments can be submitted via mail, email or fax. Submitted comments should indicate if the comments are confidential or should be available for public review.

By Mail:
Certified Equity Professional Institute
Santa Clara University
500 El Camino Real
Santa Clara, CA 95053-0400

By Email:
Research_CEPI@scu.edu

By Fax:
408/554-5143

About the Certified Equity Professional Institute
The Certified Equity Professional Institute (CEPI) at Santa Clara University is the only source of professional certification for equity compensation professionals. The CEPI is a non-profit, academic organization with a mission of establishing, promoting, and providing certification and continuing education for the equity compensation industry.

Since its founding in 1989, the CEP Institute self-study curriculum has served as the industry’s educational standard. Organizations and individuals use Institute exams as a measurement of basic (Level I), intermediate (Level II), and advanced (Level III) knowledge, skills, and abilities related to equity compensation administration. The CEPI curriculum covers accounting, corporate and securities laws, taxation, and administrative and contractual considerations, ensuring that CEP designees have achieved a required level of expertise in all of the relevant areas of equity compensation. More than 65 percent of the Fortune 1000 companies have CEPs supporting their stock plans.

As the only source of professional certification in equity compensation, the CEPI recognizes and understands the critical need for impartial guidance in this area. The CEPI has undertaken the research associated with this project with an open public comment to provide such guidance. This research of the CEPI is underwritten by Fidelity Investments.