Imagine a non-executive (aka normal Joe), who works in engineering at Apple. Per the SEC/Company policy, he can not do $AAPL trades during blackout periods. However, does this also prevent him from buying/selling major tech ETFs like $QQQ? What about broader ETFs like $SPY?

Does SEC have rules for this?

Edit: changed janitor to engineering

  • 2
    Does Apple really have a policy that employees with no access to insider information have trading windows (or, equivalently, blackout days)? I haven’t heard of that in other high tech companies.
    – prl
    Jan 3, 2020 at 9:20
  • 2
    I once was in a company meeting where someone asked the CEO a very specific financial question, and the answer was "if you really want to know, I can tell you, but I would have to record your name so you are not allowed to trade in the next blackout period".
    – gnasher729
    Jan 3, 2020 at 11:01

1 Answer 1


According to a New York Times article from last year

Apple’s insider trading policy said any individual with material, nonpublic information about the company was not allowed to trade the stock until 60 hours after that information had been announced.

From researching Blackout Period Procedures it appears that only specific reference is made to the company's stock, not any security that contains the stock of the company.

directors, officers, employees and/or affiliated persons ... may not engage in any transaction in the Company’s securities (including a gift, contribution to a trust or similar transfer)

It also appears that it is up to the company to set the blackout periods, and restrictions on general insider trading.

So to answer your question, it does not appear that the SEC specifically has a rule against this, however it would be best for someone in this situation to consult the appropriate person at their company before engaging in any trades.

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