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Code M: Exempt exercise or conversion under Rule 16b-3

Short-swing exempt
21.8%of all 2025 Form 4 transactions
14.4%of Table I lines (non-derivative)
41.7%of Table II lines (derivative)
83,684transaction lines filed
Exercise or conversion of derivative security exempted pursuant to Rule 16b-3

Use it when

  • Exercising a stock option granted under a Rule 16b-3 exempt plan.
  • Converting a convertible security under a Rule 16b-3 exempt arrangement.
  • Converting securities from an A-code grant that are now being exercised.

EDGAR expects

Table IIDisposition of the derivative security
Table IAcquisition of the underlying Table I security equivalent to the (conversion ratio x Table II securities converted)
CodeM
Disposed (Table II)D, disposition of the derivative
Acquired (Table I)A, acquisition of the underlying security
Conversion or exercise pricePopulated here
Price of derivative security columnLeave blank

What the footnote typically covers

  • What is the conversion or exercise price?
  • What is the date exercisable and expiration date for the derivative?
  • What is the title and amount of the underlying security received?
  • What is the conversion ratio of the derivative security to the underlying security?

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Related codes

Based on all 383,732 transaction lines reported on original Form 4 filings in calendar year 2025 (279,260 in Table I, 104,472 in Table II). Holdings lines and amendments are excluded. Tallied from the SEC's Insider Transactions Data Sets.

Updated August 2026
Disclaimer

General information about SEC reporting mechanics, not legal advice. Confirm treatment with counsel before filing.