Rule 16a-4
  Derivative Securities
a. For
purposes of
section 16
of the Act, both derivative securities and the underlying securities to
which they relate shall be deemed to be the same class of equity securities,
except that the acquisition or disposition of any derivative security
shall be separately reported.
b.
The exercise or conversion
of a call equivalent position shall be reported on Form 4 and be treated
for reporting purposes as:
1. A
purchase of the underlying security; and
2. A
closing of the derivative security position.
c.
The exercise or conversion
of a put equivalent position shall be reported on Form 4 and shall be
treated for reporting purposes as:
1. A
sale of the underlying security; and
2. A
closing of the derivative security position.
d. The
disposition or closing of a long derivative security position, as a result
of cancellation or expiration, shall be exempt from
section
16(a) of the Act if exempt from
section
16(b) of the Act pursuant to Rule .
Note: Under
Rule 16b-6(b),
a purchase or sale resulting from an exercise or conversion of a derivative
security generally is exempt from
section
16(b) of the Act.
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