Interesting read. https://www.debevoise.com/ins

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Section 16 Filing Requirements
New directors, new officers, and new significant shareholders must file Form 3 within 10 days of acquiring such investment assets. If there is a material change in the holdings of a company's insiders, they must file Form 4 with the SEC.

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these actions reaffirm the SEC’s long established stance that reporting persons cannot discharge their filing responsibilities by tasking the issuer, broker or outside counsel to handle the filings, while issuers that assume such responsibility may also be held accountable for negligently contributing to the insiders’ reporting violations.

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In the case of the Section 16(a) reports, insiders were a combination of officers, directors or 10% beneficial owners of public companies, with delinquent Form 4 filings ranging from one day to more than three years late. The transactions covered by the delinquent reports involved both open market and privately negotiated sales and purchases, as well as equity grants and transactions pursuant to Rule 10b5-1 plans. Each individual was also found to have failed to file one or more Form 5 filings to report the transactions in the prior year that should have been reported on Form 4.

Regarding Section 13(d) reports, deficiencies included failing to timely amend Schedule 13G as a result of material increases or decreases in ownership, failing to file Schedule 13D upon becoming a greater than 5% owner and failing to file on Schedule 13D upon losing eligibility to file on Schedule 13G under Rule 13d-1(c).

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