The Uncommon Form 4 Transaction Codes
- Use these codes when the transaction is not a plain purchase, sale, grant, or routine exercise.
- Several sit in the derivative securities family (E, H, O) and pair conceptually with codes covered elsewhere (E with H, O with X).
- Two of the ten, K and V, are not transaction codes, rather they modify or flag another code.
- The SEC's own filing data bears that out: neither letter appears as a transaction code at all. The equity swap flag that K marks was set on 0.40% of 2025 transaction lines, and 0.73% were flagged as reported early, which is what V marks on the form.
- Section16agent.com recommends consulting with an experienced securities attorney before using any of these uncommon Form 4 transaction codes; their usage is rare and unusual.
E
Used when a short derivative position, an obligation such as a written call or put, lapses unexercised.
Derivative Securities Codes (Except for transactions exempted pursuant to Rule 16b-3)
Not short-swing exempt0.02% of all 2025 transactions · <0.01% of Table I · 0.07% of Table IIExpiration of short derivative position
H
Used when a long derivative position, a held right such as a purchased call or put, expires or is canceled and the holder receives value for it.
Derivative Securities Codes (Except for transactions exempted pursuant to Rule 16b-3)
Not short-swing exempt<0.01% of all 2025 transactions · 0% of Table I · 0.02% of Table IIExpiration (or cancellation) of long derivative position with value received
I
Used for a discretionary transaction that Rule 16b-3(f) treats as exempt.
Rule 16b-3 Transaction Codes
Short-swing exempt0.08% of all 2025 transactions · 0.06% of Table I · 0.13% of Table IIDiscretionary transaction in accordance with Rule 16b-3(f) resulting in acquisition or disposition of issuer securities
L
Used for an acquisition that qualifies for the small acquisition reporting deferral under Rule 16a-6, once the deferral no longer applies and the acquisition lands on a Form 4.
Other Section 16(b) Exempt Transaction and Small Acquisition Codes (except for Rule 16b-3 codes above)
Short-swing exempt0.12% of all 2025 transactions · 0.16% of Table I · 0% of Table IISmall acquisition under Rule 16a-6
O
Used when a derivative security is exercised while out-of-the-money.
Derivative Securities Codes (Except for transactions exempted pursuant to Rule 16b-3)
Not short-swing exempt<0.01% of all 2025 transactions · <0.01% of Table I · <0.01% of Table IIExercise of out-of-the-money derivative security
U
Used when shares are disposed of by tendering them as part of a change of control transaction.
Other Transaction Codes
Not short-swing exempt0.10% of all 2025 transactions · 0.13% of Table I · <0.01% of Table IIDisposition pursuant to a tender of shares in a change of control transaction
W
Used for a transfer of securities through inheritance, by will or by the laws of descent and distribution.
Other Section 16(b) Exempt Transaction and Small Acquisition Codes (except for Rule 16b-3 codes above)
Not short-swing exempt0.02% of all 2025 transactions · 0.03% of Table I · <0.01% of Table IIAcquisition or disposition by will or the laws of descent and distribution
Z
Used when securities move into or out of a voting trust.
Other Section 16(b) Exempt Transaction and Small Acquisition Codes (except for Rule 16b-3 codes above)
Not short-swing exempt<0.01% of all 2025 transactions · <0.01% of Table I · 0.01% of Table IIDeposit into or withdrawal from voting trust
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