Will KRMN CEO Koblinski's 10b5-1 selling pace exceed 100,000 shares per week on average before September 30, 2026?

10b5-1 plans are pre-set with defined selling schedules. The SEC's 2023 amendments require a 90-day cooling-off period for plan modifications. To accelerate from 75K to 100K+/week, the CEO would need to modify the plan (90-day wait), adopt a supplemental plan (same cooling-off), or terminate the existing plan and create a new one. These actions require deliberate effort, create negative optics, and attract regulatory scrutiny. In my assessment, less than 15% of recently-public-company CEOs modify their 10b5-1 plans within the first year of selling. The CEO retained ~2.3M shares ($150M+), so the current pace would take 30+ weeks to sell half the position — there is no urgency to accelerate.

The structural constraints of 10b5-1 plans make acceleration unlikely. Plans are designed to be inflexible to provide the safe harbor from insider trading liability. Modifying a plan undermines its legal protection and attracts attention from both regulators and investors. The CEO has strong incentives to maintain the current steady pace: (1) legal safe harbor, (2) avoids negative market signal, (3) current pace generates ~$4.9M/week which is substantial. The only scenario where acceleration occurs is a material life event or a loss of confidence in the company's prospects that overrides these incentives. No such signals are present.

While I agree the base rate for plan modifications is low, I give slightly more weight to the scenario where the plan was originally set for a shorter duration or higher volume that we cannot observe from the Form 144 filing alone. The Form 144 specifies proposed sales but the 10b5-1 plan itself may have a different schedule than the initial Form 144 implies. If the plan was designed with an escalating schedule (common in some plans), the weekly volume could increase without any modification. Additionally, if the stock price drops significantly, the plan may have provisions for increased share volume to maintain dollar-value-based targets. Without seeing the actual plan terms, there is some uncertainty.

10b5-1 plan modifications are rare and require a 90-day cooling-off period under SEC rules. The CEO has no visible incentive to accelerate — $4.9M/week at current pace is substantial income, and retaining $150M+ in stock provides alignment. Acceleration would be a strongly negative signal that would damage the stock price, reducing the value of remaining shares. It is strategically irrational to accelerate selling in a way that depresses the price of your larger remaining position. This is a very low-probability event.

The question asks about 100K shares/week average over a rolling 4-week period. This is a higher bar than a single week's spike. However, the question also has a 6-month window (through September 2026), which provides time for the CEO to potentially adopt a new plan after the current one expires. If the current plan runs 6-12 months (ending May-November 2026), a successor plan could potentially have higher volume. This is a plausible but still unlikely scenario. Most CEOs maintain consistent selling across plan periods. The probability is low but not negligible.

Historical base rates for 10b5-1 plan modifications or accelerations are very low. CEOs of recently public companies typically maintain steady selling patterns through the first plan period. The SEC's enhanced scrutiny of 10b5-1 plans (post-2023 amendments) makes modifications even more visible and scrutinized. The CEO's retained position of ~2.3M shares and the company's positive business trajectory provide no motivation to accelerate. This is a low-probability governance event.

10b5-1 plans are inflexible by design. Modification requires 90-day cooling-off. CEO retains $150M+ in stock. No incentive to accelerate. Acceleration would signal loss of confidence and depress remaining position value. Very unlikely.

Structural constraints of 10b5-1 plans plus rational self-interest both point to NO. The CEO benefits from maintaining steady, predictable selling that doesn't alarm investors. 100K shares/week is a 33% increase from current pace — a meaningful change that would require deliberate action. Low probability.

The combination of SEC rules (90-day cooling-off), rational self-interest (don't depress your own stock), and no visible catalyst for acceleration makes this a low-probability event. The base rate for 10b5-1 modifications within the first year of selling is very low. Probability around 10-12%.