(a) For purposes of section 16 of the Act, both derivative securities and the underlying securities to which they relate shall be deemed to be the same class of equity securities, except that the acquisition or disposition of any derivative security shall be separately reported.

          (b) The exercise or conversion of a call equivalent position shall be reported on Form 4 and be treated for reporting purposes as:

               (1) A purchase of the underlying security; and

               (2) A closing of the derivative security position.

          (c) The exercise or conversion of a put equivalent position shall be reported on Form 4 and shall be treated for reporting purposes as:

               (1) A sale of the underlying security; and

               (2) A closing of the derivative security position.

          (d) The disposition or closing of a long derivative security position, as a result of cancellation or expiration, shall be exempt from section 16(a) of the Act if exempt from section 16(b) of the Act pursuant to Rule 16b-6(d).

           Note: Under Rule 16b-6(b), a purchase or sale resulting from an exercise or conversion of a derivative security generally is exempt from section 16(b) of the Act.