Many employees of public companies have trading restrictions to trade their employer's stock because they have inside knowledge. For simplicity let's assume I'm an Apple employee and only allowed to trade in the month after a quarterly report has come out.
I also have investments (e.g. 401k, IRA) in various mutual funds and ETF, some of which also hold and trade Apple stock. When I buy/sell any of these funds or the funds themselves buy/sell Apple stock, I'm technically trading Apple stock outside the legal trading window. Is this a violation of SEC rules?
I'm guessing it's fine, since the Apple portion of my direct or indirect trades is heavily diluted by the other holdings of the ETF but I would like to know :
- If you are legally restricted by trading a specific stock, can you still buy, sell, or own mutual funds or ETFs that trade/hold this specific stock ?
- If the answer to 1) is "mostly yes", what are some specific circumstances or trigger points that would make it a "no"?
- If the answer is "no", what is the expectation for Apple employees to manage their investments? Finding funds or ETFs that don't hold any Apple is kind of difficult :-)
@mods: If this is a better fit for http://law.stackexchange.com/ feel free to move it or I can move it myself. Thanks !