SEC Form 4 Transaction Codes: Complete Reference Guide

Last updated: April 03, 2026

When corporate insiders (officers, directors, and large shareholders) buy, sell, or otherwise transact in their company's securities, they must file a Form 4 with the SEC within two business days. Each transaction is tagged with a single-letter transaction code that describes the nature of the trade.

Understanding these codes is essential for interpreting insider activity. Not all insider transactions are equal — an open-market purchase (code P) carries a very different signal than an automatic tax withholding (code F).

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Quick Reference Table

Code Transaction Type Signal Strength Description
P Open-market purchase Strong bullish Insider voluntarily buys shares on the open market using their own money.
S Open-market sale Moderate Insider sells shares on the open market. Can be bearish, but insiders sell for many reasons.
A Grant, award, or other acquisition Weak / Routine Insider receives shares from the company as compensation (stock awards, RSUs, bonus shares).
D Disposition (sale back to company) Weak / Routine Insider sells or transfers shares back to the issuing company (e.g., share buyback).
F Tax withholding Routine Company withholds shares to cover tax obligations when shares vest or options are exercised. Not a voluntary sale.
M Exercise/conversion of derivative Weak / Routine Insider exercises stock options or converts a derivative security into common stock.
C Conversion of derivative Weak Conversion of a derivative security (e.g., convertible note to common stock).
X Exercise of in-the-money derivative Routine Exercise of an in-the-money or at-the-money derivative security.
O Exercise of out-of-money derivative Weak Exercise of an out-of-the-money derivative security.
E Expiration (short position) Informational Expiration of a short derivative position.
H Expiration (long position) Informational Expiration of a long derivative position.
G Gift No signal A bona fide gift of securities, either by or to the insider (e.g., charitable donation).
K Equity swap Moderate Equity swap or similar hedging transaction. May indicate the insider is reducing risk exposure.
V Voluntary report Informational A transaction voluntarily reported on Form 4 (not legally required to be reported).
J Other Varies Other types of transactions described in footnotes.
I Discretionary transaction Weak Discretionary transaction in an issuer plan.
L Small acquisition Weak Small acquisition under Rule 16a-6.
U Tender offer disposition Moderate Disposition pursuant to tender of shares in a change of control transaction.
W Inheritance No signal Acquisition or disposition by will or the laws of descent and distribution.
Z Voting trust Informational Deposit into or withdrawal from a voting trust.

Most Important Codes for Investors

Code P - Open Market Purchase

This is widely considered the strongest bullish signal in insider trading analysis. When an insider spends their own money to buy shares on the open market, they are making a bet that the stock price will rise. Studies have shown that stocks with significant insider buying tend to outperform the market.

Example: A CEO purchases 50,000 shares of their company at $25.00 per share, spending $1,250,000 of their own money. This appears as code "P" on Form 4.

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Code S - Open Market Sale

Insider sells are harder to interpret than buys. Insiders sell for many legitimate reasons: diversification, tax planning, personal expenses, pre-planned 10b5-1 trading plans, or estate planning. However, cluster selling (multiple insiders selling around the same time) or unusually large sales can be a warning sign.

Example: A CFO sells 10,000 shares at $48.50 per share. This could be a pre-planned sale under a 10b5-1 plan, or it could reflect reduced confidence. Context matters.

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Code M - Option Exercise

Option exercises are generally routine and tied to compensation packages. They often appear alongside code "S" transactions when insiders exercise options and immediately sell the shares ("exercise and sell"). The key distinction: watch whether the insider holds or sells the shares after exercising.

Example: A VP exercises 20,000 stock options at a strike price of $15.00 (code M), then immediately sells 20,000 shares at $30.00 (code S) to cover the exercise cost and taxes.

Code F - Tax Payment via Share Withholding

Code F transactions are not voluntary sales and should not be interpreted as bearish signals. When restricted stock units (RSUs) vest, the company withholds a portion of shares to cover the insider's tax liability. The insider has no discretion over this transaction.

Example: An executive's 10,000 RSUs vest. The company withholds 3,700 shares (code F) to cover ~37% income tax, and the executive receives the remaining 6,300 shares.

How to Use Transaction Codes in Your Analysis

  1. Focus on P and S codes for directional signals. Other codes are mostly routine or administrative.
  2. Look at clusters — multiple insiders buying or selling around the same time is more meaningful than a single transaction.
  3. Consider the dollar amount — a $2 million purchase by a CEO is a stronger signal than a $10,000 purchase by a minor officer.
  4. Check the percentage — an insider increasing their position by 50% is more notable than a 1% increase.
  5. Filter out noise — ignore F (tax), A (grants), and M (exercises) unless the insider holds the shares.
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Frequently Asked Questions

What is SEC Form 4?

Form 4 is a filing required by the SEC whenever a company insider (officer, director, or 10%+ shareholder) changes their ownership position in the company's securities. It must be filed within two business days of the transaction.

Is insider trading legal?

Yes, most insider trading is perfectly legal. Corporate insiders are allowed to buy and sell their company's stock, as long as they don't trade on material non-public information. All legal trades must be disclosed via Form 4 filings. It's only illegal when insiders trade based on confidential information not available to the public.

What is a 10b5-1 plan?

A 10b5-1 plan is a pre-arranged trading plan that allows insiders to set up automatic trades in advance. These plans provide a legal defense against insider trading accusations because the trades are predetermined. Sales under 10b5-1 plans are generally considered less meaningful as bearish signals.

Where does Insidersy get its data?

All data comes directly from SEC EDGAR, the SEC's Electronic Data Gathering, Analysis, and Retrieval system. We parse Form 4 XML filings as they are published and extract the transaction details for easy filtering and analysis.