January 12, 2026

To Our Clients and Friends:

Banks that allow employees to purchase employer stock through incentive stock options (“ISOs”) or an employee stock purchase plan (“ESPP”) should be aware of the upcoming February 2, 2026 deadline for employers to deliver a completed Form 3921 or 3922 to employees, setting forth the details of the employee’s 2025 exercise of ISOs or purchase of shares through an ESPP, respectively.  Shortly thereafter, the employer must also file the IRS Form 3921 or 3922 with the IRS.  Our Legal Update covering these requirements is available here.

Luse Gorman, PC regularly advises companies regarding corporate governance, shareholder matters and SEC developments. If you have any questions related to this Legal Update, please reach out to your usual firm contact. To learn more about our firm and services, please visit our website.

View PDF