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And management chooses the underwriters, who therefore will conform their requirements to management's demands, as they have here.

Underwriters frequently try to impose lockouts, but its the management who actually sets the terms, which is why some lockouts are as short as 3 months while others are as long as 9 months. There is no requirement that the lockouts apply equally to management/dominant shareholders and other shareholders, though management frequently accept such restrictions b/c its not usually worth the cost to carve out such an exception.



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