> And transferring shares to a trust doesn’t relieve the trust of public reporting requirements when the insider is still responsible for the trust. It looks l

> And transferring shares to a trust doesn’t relieve the trust of public reporting requirements when the insider is still responsible for the trust. It looks like TFA author is correct that they structured the transfer specifically to avoid Meckenzie or the trust falling within the definition of “beneficial ownership” that would trigger a 13D reporting obligation and since they transferred 0.7% of outstanding shares (less than 1% with a bit of wiggle room for market movement) I’m assuming the shares were transferred to an irrevocable trust so they’d be outside the scope of Form 4 unless he’s serving as trustee which is unlikely (although, not entirely impossible) judging by the way the disclosure is phrased in his SEC filing: > On May 26, 2021, Mr. Meckenzie transferred his beneficial interest in 19,075,875 shares of Common Stock (the “Shares”) for no consideration to a trust for the benefit of his spouse and children and remoter issue and for which an independent trustee has been appointed (the “Trust”), and the Trust immediately transferred the Shares to a company (the “Company”) wholly-owned by the Trust (the “Transfers”). Mr. Meckenzie does not exercise voting or dispositive power over the Shares or have a right to reacquire the Shares. As a result of the Transfers, Mr. Meckenzie no longer has or shares, directly or indirectly, voting or investment power over the Shares. If he’s acting as co-trustee alongside an independent trustee and phrasing it in such a way to insinuate he’s not at all involved that would be very shady indeed.