Exhibit 19 Insider Trading Policies Dataset (2023-Present)

The Exhibit 19 Insider Trading Policies dataset contains corporate insider trading policy documents filed as Exhibit 19 attachments on EDGAR pursuant to Regulation S-K, Item 601(b)(19). Each record is a single exhibit file — in HTML or PDF format, packaged in a ZIP container — representing one company's insider trading policy as disclosed in an annual report or other EDGAR filing. The dataset begins in 2023, when disclosure became mandatory under the SEC's 2022 final rule on Insider Trading Arrangements and Related Disclosures (Release No. 33-11138; 34-96492). It covers all parent filing types in which Exhibit 19 appears, including Forms 10-K, 20-F, 40-F, 10-Q, S-4, and 8-K, along with their amended variants. The dataset currently contains over 6,300 records totaling approximately 127 MB and is updated continuously as new EDGAR filings are processed.

Dataset APIs

Dataset Files

What This Dataset Contains

Each record is a single insider trading policy document extracted from an SEC EDGAR filing and delivered as an HTML or PDF file inside a monthly ZIP container. The underlying document is the corporate insider trading policy that a registrant must disclose under Regulation S-K, Item 601(b)(19), effective for fiscal years beginning on or after April 1, 2023. The dataset collects the actual filed exhibit attachment — the full policy document — along with a structured metadata.json file containing filing and company identifiers.

The dataset is organized into monthly ZIP containers named by year and month (e.g., 2025-09.zip). Each ZIP contains a top-level folder (e.g., 2025-09/) with one subfolder per filing, named by the 18-digit zero-padded accession number (dashes removed). Each subfolder contains exactly two files:

1. metadata.json — structured JSON with filing metadata and company identifiers
2. An .htm or .pdf file — the actual Exhibit 19 insider trading policy document as filed on EDGAR

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          2025-09.zip
        

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            └── 2025-09/
        

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                  ├── 000110465925093884/
        

          4
                  │     ├── metadata.json
        

          5
                  │     └── mara-20250630xex19.htm
        

          6
                  ├── 000001673225000112/
        

          7
                  │     ├── metadata.json
        

          8
                  │     └── cpb-832024x10xkxexb19.htm
        

          9
                  └── ... (one folder per filing)
        

Before the SEC's 2022 final rule on Insider Trading Arrangements and Related Disclosures, corporate insider trading policies were internal documents rarely disclosed publicly in any standardized form. The Exhibit 19 mandate created, for the first time, a comprehensive and publicly accessible repository of these compliance documents across the full EDGAR filing population.

A typical insider trading policy addresses the following areas:

• Scope and covered persons — officers, directors, employees, contractors, consultants, household and family members of insiders, and entities controlled by covered persons.
• Definition of material nonpublic information (MNPI) — how the company defines MNPI, typically with examples of presumptively material information: earnings results, mergers and acquisitions, executive leadership changes, regulatory actions, cybersecurity incidents, significant contracts, and restatements.
• Trading restrictions — blanket prohibitions on trading while aware of MNPI, plus specific prohibited transaction types such as short sales, puts, calls, hedging transactions (including prepaid variable forwards and equity swaps), margin accounts, and pledging of company securities.
• Blackout periods — quarterly trading blackout windows (commonly beginning two weeks before quarter-end and lasting until one to two trading days after earnings release), event-specific blackouts imposed by the general counsel or chief compliance officer, and rules governing blackout start and end dates.
• Pre-clearance requirements — mandatory pre-clearance procedures for designated insiders (typically Section 16 reporting persons and sometimes other senior employees), specifying the approving authority (general counsel, compliance officer, or designee) and the approval validity window (often 24-48 hours or until the next blackout).
• Rule 10b5-1 plan provisions — rules governing the adoption, modification, and termination of Rule 10b5-1 trading plans, including company-specific cooling-off periods, restrictions on overlapping plans, prohibitions on single-trade plans, and good-faith certification requirements.
• Post-termination obligations — whether and for how long trading restrictions continue after an insider's departure (commonly 90 days to six months).
• Exceptions and permitted transactions — carve-outs for employee stock option exercises, ESPP payroll deductions, 401(k) and ESOP transactions, bona fide gifts, inheritance transfers, and domestic relations orders.
• Reporting and certification obligations — requirements for covered persons to report transactions, certify annual compliance, and acknowledge receipt of the policy.
• Sanctions and enforcement — consequences for violations, including disciplinary action up to termination, disgorgement or clawback of trading profits, and referral to regulatory or law enforcement authorities.

Content Structure of a Single Record

Each record consists of a metadata.json file and the Exhibit 19 document as submitted to EDGAR. The exhibit file is in HTML or PDF format and preserves the full text, formatting, headers, signatures, and appendices of the insider trading policy as the registrant filed it.

metadata.json Fields

Primary identifiers:

• id — unique record identifier (MD5 hash, e.g., 4204c5239afc85c81bac3424aa2b8fb3)
• accessionNo — SEC accession number of the parent filing (e.g., 0001104659-25-093884)
• cik — Central Index Key, the SEC's unique numeric identifier for the filing entity
• ticker — stock ticker symbol (e.g., MBBC)

Company information:

• companyName — short company name (e.g., Marathon Bancorp, Inc. /MD/)
• companyNameLong — full company name with filer designation (e.g., Marathon Bancorp, Inc. /MD/ (Filer))

Filing information:

• formType — SEC form type of the parent filing (e.g., 10-K, 10-K/A, 20-F, 40-F, 10-Q, S-4, 8-K)
• description — human-readable form description (e.g., Form 10-K - Annual report [Section 13 and 15(d), not S-K Item 405])
• filedAt — filing date and time in ISO 8601 format with timezone (e.g., 2025-09-26T16:30:42-04:00)
• periodOfReport — reporting period end date (e.g., 2025-06-30)

EDGAR links:

• linkToFilingDetails — URL to the primary filing document on EDGAR
• linkToTxt — URL to the complete submission text file
• linkToHtml — URL to the EDGAR filing index page
• linkToXbrl — URL to XBRL viewer (may be empty)

Document listings:

• documentFormatFiles — array of all documents in the filing package, including the EX-19 exhibit. Each entry includes sequence, size, documentUrl, description, and type. The exhibit entry has type set to EX-19 or EX-19.1.
• dataFiles — array of XBRL and other data files associated with the filing

Entity information:

• entities — array of entity objects with fields: cik, companyName, type, sic (industry code and description), stateOfIncorporation, fiscalYearEnd, act, fileNo, irsNo, filmNo

Exhibit 19 HTML/PDF File

The .htm or .pdf file contains the full text of the company's insider trading policy. HTML files are wrapped in SGML-style <DOCUMENT> tags with <TYPE>EX-19 headers (the standard EDGAR document envelope format). The content typically includes policy title and effective date, trading restrictions, blackout period definitions, pre-clearance requirements, hedging and pledging prohibitions, Rule 10b5-1 plan provisions, MNPI definitions, penalties for violations, post-termination restrictions, and compliance officer contact information.

The dataset does not parse the policy text into structured fields. Each record delivers the raw exhibit document along with its structured metadata. Users who want structured extractions — for example, whether a policy prohibits hedging, the length of the blackout period, or the cooling-off period for 10b5-1 plans — must apply their own text parsing, NLP, or manual review.

What Is Included

• All Exhibit 19 attachments filed on EDGAR from the earliest available filings (March 2023 onward).
• Exhibits from all parent form types: 10-K, 10-K/A, 10-KT, 10-KT/A, 20-F, 20-F/A, 40-F, 40-F/A, 10-Q, 10-Q/A, S-4, S-4/A, and 8-K.
• Both HTML and PDF file formats as filed by the registrant.

What Is Excluded

• Narrative insider trading policy descriptions embedded in the body of the filing (e.g., Item 10 of Form 10-K) without a separate Exhibit 19 attachment.
• Policies disclosed voluntarily before the Exhibit 19 mandate took effect, even if filed as a different exhibit type or included in a proxy statement.
• Structured or parsed extractions of individual policy provisions — the dataset provides raw document files only.

Important Formatting and Content Nuances

Format variability: Exhibit 19 policies range from two-page summaries to 20+ page compliance manuals with appendices, employee certification forms, FAQ sections, and specimen pre-clearance request forms. Some are clean HTML; others are PDF scans of board-approved originals with signatures. No SEC-mandated template exists for the policy content.

Policy versioning: When a company updates its insider trading policy, the revised version is filed as Exhibit 19 in the next annual report. The dataset may contain multiple versions of the same company's policy across successive fiscal years, enabling longitudinal analysis of policy evolution. Amended filings (10-K/A, 20-F/A) may also contain corrected or updated Exhibit 19 attachments.

Incorporation by reference: Some registrants incorporate Exhibit 19 by reference to a prior filing rather than re-filing the document. The dataset may not contain a separate file for the referencing filing if no new exhibit document was uploaded.

Multi-entity policies: Holding companies and conglomerates sometimes file a single policy covering all subsidiaries. The document may name multiple entities but appears as one Exhibit 19 attached to the parent company's filing.

No confidential treatment: Insider trading policies are not eligible for confidential treatment. The full text of every filed Exhibit 19 is publicly available on EDGAR without redaction.

Who Files Exhibit 19 and When

Filer Population

Every SEC reporting company that maintains an insider trading policy must disclose it as Exhibit 19 to its annual report. The filer population encompasses:

• Domestic operating companies filing Form 10-K — large accelerated filers, accelerated filers, non-accelerated filers, smaller reporting companies, and emerging growth companies across all industries and exchanges.
• Foreign private issuers filing Form 20-F — non-U.S. companies listed on U.S. exchanges, subject to the same requirement.
• Canadian cross-listed issuers filing Form 40-F — Canadian companies using the Multijurisdictional Disclosure System (MJDS).
• Transition-period filers filing Form 10-KT — companies changing their fiscal year-end.

Companies that do not maintain an insider trading policy must disclose that fact in the body of the filing (Item 10 of Form 10-K), although no Exhibit 19 is filed in that case.

Regulatory Basis

The Exhibit 19 requirement was established by the SEC's December 2022 final rule titled "Insider Trading Arrangements and Related Disclosures" (Release No. 33-11138; 34-96492). The rule amended Regulation S-K, Item 601(b) to add paragraph (19), requiring registrants to file insider trading policies and procedures as an exhibit to annual reports on Forms 10-K, 20-F, and 40-F.

This rule was part of a broader insider trading transparency reform that also introduced disclosure requirements for Rule 10b5-1 trading plan events (Item 408(a) of Regulation S-K), expanded mandatory cooling-off periods for new or modified 10b5-1 plans, and required quarterly disclosure of director and officer trading arrangements. The requirement is grounded in Section 10(b) of the Securities Exchange Act of 1934, Rule 10b-5, and the SEC's authority under Section 16 of the Securities Exchange Act of 1934 and the broader antifraud provisions.

Effective Date and First Filings

The Exhibit 19 requirement applies to annual reports for fiscal years beginning on or after April 1, 2023. The earliest filers were companies with non-calendar fiscal years starting shortly after that date. The large wave of calendar-year filers (fiscal year ending December 31, 2024) filed their first Exhibit 19 with 10-K filings in the February-April 2025 window. The dataset begins with records from March 2023 and captures all Exhibit 19 filings from the earliest EDGAR submissions onward.

Filing Triggers and Cadence

Annual filing: The primary trigger is the annual report. Exhibit 19 is filed once per year as an attachment to the 10-K, 20-F, or 40-F.

Amended annual reports: A 10-K/A, 20-F/A, or 40-F/A may include an updated or corrected Exhibit 19 when the original was deficient or the policy was revised after initial filing.

Other form types: Exhibit 19 also appears in 10-Q, S-4, and 8-K filings — in quarterly reports when a company updates its policy mid-year, in S-4 registration statements disclosing the combined entity's policy in a merger, and in 8-K filings when a material event triggers an interim policy update.

Filing Deadlines

Exhibit 19 follows the parent annual report deadline: 60 days for large accelerated filers, 75 days for accelerated filers, 90 days for non-accelerated filers (all Form 10-K), and four months for foreign private issuers (Form 20-F). The policy must be current as of the filing date.

Dataset Growth

The dataset contains over 6,300 records as of late March 2026. As subsequent annual reporting cycles complete, it will grow by roughly 4,000-6,000 new records per year and will accumulate multiple policy versions per company over time.

How This Dataset Differs from Related SEC Filings and Datasets

Exhibit 19 vs. Item 10 Insider Trading Narrative (Form 10-K Body Text)

The 2022 final rule created two complementary disclosures: a narrative summary in Item 10 of the annual report and the full policy document as Exhibit 19. The narrative is typically a few sentences confirming the policy exists and describing its general scope. Exhibit 19 is the operative legal document with all specific provisions, definitions, blackout schedules, pre-clearance procedures, 10b5-1 plan rules, and enforcement mechanisms.

Exhibit 19 vs. Section 16 Ownership Filings (Forms 3, 4, and 5)

Section 16 filings report actual insider transactions — purchases, sales, option exercises, and other ownership changes. Exhibit 19 discloses the rules governing those transactions. The policy is the governance framework; Section 16 filings are the transaction record. Researchers studying compliance need both.

Exhibit 19 vs. Rule 10b5-1 Plan Disclosures (Item 408(a))

Item 408(a) disclosures report individual plan adoptions, modifications, and terminations by directors and officers. Exhibit 19 establishes the company-wide policy governing how all 10b5-1 plans must be structured — including company-imposed cooling-off periods, restrictions on overlapping plans, and approval requirements. Item 408(a) is person-specific; Exhibit 19 is policy-level.

Exhibit 19 vs. Proxy Statement Governance Disclosures (DEF 14A)

Proxy statements sometimes included abbreviated insider trading policy descriptions in their governance sections, but these were voluntary and non-standardized. Exhibit 19 is the mandated, authoritative source for the full policy document.

Exhibit 19 vs. Code of Ethics (Exhibit 14)

Exhibit 14 covers broad conduct standards under Item 406 of Regulation S-K and Section 406 of the Sarbanes-Oxley Act. Some codes mention insider trading briefly. Exhibit 19 is the targeted, detailed insider trading compliance program.

Exhibit 19 vs. Form 144

Form 144 reports proposed sales of restricted or control securities under Rule 144. It is a transaction-level notice. Exhibit 19 establishes the policy framework determining whether such transactions are permitted.

What Makes This Dataset Distinct

This is the only standardized, machine-accessible collection of corporate insider trading policy documents across the SEC reporting population. The mandatory Exhibit 19 filing created a comprehensive, comparable, and continuously updated corpus enabling systematic cross-company analysis, longitudinal tracking, and large-scale NLP research on insider trading governance for the first time.

Who Uses This Dataset

Securities Compliance Officers and In-House Counsel

Compliance officers and general counsel benchmark their own policies against peers — comparing blackout period durations, pre-clearance scope, hedging and pledging prohibitions, 10b5-1 plan cooling-off periods, and post-termination restrictions across companies in the same industry and size range. Cross-company comparisons identify gaps and support board-level policy update recommendations.

Securities Enforcement Attorneys

SEC Division of Enforcement attorneys and DOJ prosecutors examine filed Exhibit 19 policies to establish what trading restrictions governed an accused insider's conduct. The filed policy serves as evidence of the company's stated rules at the time of the alleged violation.

Shareholder Litigation Attorneys

Plaintiffs' counsel in securities fraud and derivative suits use the policy to allege that insiders violated their own company's rules. Defense counsel uses the same documents to show robust compliance procedures were in place. Both sides require the actual filed policy document.

Corporate Governance Researchers and Academics

Researchers study insider trading policy design as a governance variable — testing whether policy strictness correlates with reduced insider trading activity, and analyzing how policies vary by industry, size, and governance quality. The dataset provides a large-scale text corpus for NLP and textual analysis studies that were impossible before mandatory Exhibit 19 disclosure.

Institutional Investor Governance Teams

Governance analysts at asset managers, pension funds, and proxy advisory firms evaluate policies as part of ESG and governance scoring — checking for hedging and pledging prohibitions, employee coverage scope, and 10b5-1 plan provisions against best-practice standards.

M&A and Capital Markets Counsel

Outside counsel uses the dataset for governance due diligence in acquisitions and IPO preparation — reviewing target companies' policies for compliance gaps, integration issues, and alignment with exchange listing standards.

Compliance Technology Vendors

Regtech companies building pre-clearance platforms and policy management tools use the corpus to understand the range and structure of insider trading policies, informing product design and training NLP extraction models.

Executive Compensation Consultants

Compensation consultants review peer-company policies to understand how trading restrictions affect the realized value of executive equity awards — advising on whether blackout periods, hedging prohibitions, and pledging restrictions are competitive within an industry.

Financial Journalists

Reporters covering insider trading cases and corporate governance use Exhibit 19 filings to verify what a company's rules actually required at the time of an alleged violation.

Specific Use Cases

1. Benchmarking Blackout Period Duration Across Industries

A compliance officer downloads Exhibit 19 documents from companies in the same SIC code, extracts blackout period language using keyword search or NLP, and compiles a distribution of blackout start rules (14 days vs. 30 days before quarter-end) and end rules (one vs. two trading days after earnings release). The analysis identifies whether the company's blackout window is shorter than the industry norm, supporting a recommendation to the board's compliance committee.

2. Enforcement Investigation — Identifying Hedging Prohibitions

An SEC enforcement attorney investigating suspicious trading by a corporate officer retrieves the company's Exhibit 19 from the dataset. The filed policy explicitly prohibits prepaid variable forward contracts, equity swaps, and collars — establishing that the officer's hedge position violated the company's stated rules and supporting the case for scienter.

3. NLP Study of Policy Strictness and Trading Outcomes

An academic research team builds a policy-strictness index by computationally scoring every Exhibit 19 document on dimensions including blackout length, pre-clearance scope, hedging prohibition, pledging prohibition, cooling-off period, post-termination restriction duration, and sanction severity. They merge this index with Section 16 Form 4 transaction data to test whether stricter policies reduce abnormal returns around insider trades.

4. Governance Due Diligence in an Acquisition

Outside counsel for an acquirer downloads the target's Exhibit 19 filing. The policy review reveals no 10b5-1 cooling-off period beyond the SEC minimum, permitted pledging with board approval, and exempted stock option exercises from pre-clearance. Counsel flags these as governance gaps for post-closing remediation in the merger integration plan.

5. Proxy Advisory Firm Governance Scoring

A governance analyst scores the Russell 3000 on five insider trading policy criteria: hedging prohibition, pledging prohibition, all-employee coverage, Section 16 pre-clearance requirement, and above-minimum 10b5-1 cooling-off period. Companies meeting all five receive a top governance score. The scores feed into proxy voting recommendations and published governance ratings.

6. Tracking Policy Evolution After Regulatory Changes

A securities law researcher collects Exhibit 19 filings from the same companies across consecutive annual reports to track how policies evolved in response to the 2022 final rule — identifying which companies updated their 10b5-1 provisions, which added single-trade plan restrictions, and which re-filed existing policies without revision.

7. Pre-IPO Policy Drafting Using Peer Comparisons

General counsel at a pre-IPO company retrieves Exhibit 19 filings from 15-20 recently listed peer companies. The policies serve as drafting templates — identifying standard provisions, common language patterns, and market-practice approaches to blackout periods, pre-clearance, hedging prohibitions, and 10b5-1 plan governance.

Dataset Access

Dataset Index JSON API

          1
          https://api.sec-api.io/datasets/exhibit-19-insider-trading-policies.json
        

Returns metadata about the dataset and a list of all available container files. No API key is required. The response includes dataset name, description, last updated timestamp, earliest sample date, total records and total size, form types, container format (ZIP), content file types (HTML, PDF), the full dataset download URL, and a list of containers with per-container metadata (size, record count, last updated timestamp, download URL).

Use this endpoint to identify which containers have been updated since your last download for incremental synchronization.

Example response:

          1
          {
        

          2
            "datasetId": "1f11fdab-ddc9-6ec0-9e68-d345205e7489",
        

          3
            "datasetDownloadUrl": "https://api.sec-api.io/datasets/exhibit-19-insider-trading-policies.zip",
        

          4
            "name": "Insider Trading Policies - Exhibit 19 Attachments - Regulation S-K, Item 601(b)(19)",
        

          5
            "updatedAt": "2026-03-28T08:13:56.000Z",
        

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            "earliestSampleDate": "2023-03-01",
        

          7
            "totalRecords": 6266,
        

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            "totalSize": 116611952,
        

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            "formTypes": [
        

          10
              "10-K",
        

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              "10-K/A",
        

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              "10-KT",
        

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              "10-KT/A",
        

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              "20-F",
        

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              "20-F/A",
        

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              "40-F",
        

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              "40-F/A",
        

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              "10-Q",
        

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              "10-Q/A",
        

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              "S-4",
        

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              "S-4/A",
        

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              "8-K"
        

          23
            ],
        

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            "containerFormat": "ZIP",
        

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            "fileTypes": ["HTML", "PDF"],
        

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            "containers": [
        

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              {
        

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                "downloadUrl": "https://api.sec-api.io/datasets/exhibit-19-insider-trading-policies/2026/2026-03.zip",
        

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                "key": "2026/2026-03.zip",
        

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                "size": 3245678,
        

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                "records": 312,
        

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                "updatedAt": "2026-03-28T08:13:56.000Z"
        

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              }
        

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            ]
        

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          }
        

Download Entire Dataset

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          https://api.sec-api.io/datasets/exhibit-19-insider-trading-policies.zip?token=YOUR_API_KEY
        

Downloads the full dataset as a single archive containing all containers. An API key is required. The archive includes over 6,300 records totaling approximately 127 MB.

Download Single Container

          1
          https://api.sec-api.io/datasets/exhibit-19-insider-trading-policies/2026/2026-03.zip?token=YOUR_API_KEY
        

Downloads one individual container file. An API key is required. Each ZIP container holds Exhibit 19 attachment files in HTML and PDF format. Container paths follow the pattern shown in the dataset index JSON API response.

Authentication

All download endpoints require an API key passed as a query parameter (?token=YOUR_API_KEY). The dataset index JSON API endpoint does not require authentication.

Update Frequency

The dataset is updated regularly as new EDGAR filings containing Exhibit 19 attachments are processed. New exhibit files are typically available shortly after the parent filing appears on EDGAR.

FAQ

When did companies first start filing Exhibit 19?

The Exhibit 19 requirement applies to annual reports for fiscal years beginning on or after April 1, 2023. The earliest filings appeared from companies with non-calendar fiscal years. The large wave of calendar-year filers began in early 2025 with 10-K filings for fiscal year 2024.

Does every public company file Exhibit 19?

Every SEC reporting company that maintains an insider trading policy must file it as Exhibit 19. Companies that do not maintain a policy must disclose that fact in the body of the annual report but do not file an Exhibit 19 attachment. In practice, the vast majority of reporting companies maintain and file a policy.

What file formats are the policies in?

Exhibit 19 documents are filed in HTML or PDF format. Some are clean HTML documents suitable for text extraction; others are PDF scans of board-approved originals. There is no SEC-mandated template.

Can I compare the same company's policy across years?

Yes. When a company files an updated or revised policy, the new version appears as Exhibit 19 in the subsequent annual report. The dataset accumulates multiple versions per company over time, enabling longitudinal comparison of policy changes.

Does the dataset include parsed or structured policy data?

No. The dataset provides the raw exhibit document files (HTML and PDF). Users who need structured extractions — such as whether a policy prohibits hedging or the length of the blackout period — must apply their own text parsing, NLP, or manual review.

Why do some Exhibit 19 filings appear in 10-Q or 8-K filings?

While the primary mandate targets annual reports, companies occasionally file Exhibit 19 in quarterly reports (when updating a policy mid-year), in S-4 registration statements (in connection with mergers), or in 8-K filings (when a material event triggers a policy update).

How large is a typical Exhibit 19 document?

Policies range from under 5 KB (short two-page summaries) to over 500 KB (comprehensive compliance manuals with appendices and certification forms). The median file size is typically in the 20-50 KB range.

What is the difference between Exhibit 19 and the insider trading disclosure in Item 10 of the 10-K?

Item 10 contains a brief narrative summary confirming the policy exists and describing its general scope. Exhibit 19 is the full policy document with all specific provisions, restrictions, and procedures.