SEC Form 4 transaction code

Form 4 Code C: Conversion of a Derivative

Code C marks the conversion of a derivative security outside the Rule 16b-3 exemption, such as convertible preferred stock or Class B shares converted into the listed class.

“Conversion of derivative security”

SEC Form 4, General Instruction 8 (Transaction Codes), under “Derivative Securities Codes (Except for transactions exempted pursuant to Rule 16b-3)”. Form 4 and instructions (PDF, sec.gov)

How often code C appears in real filings

Share of transaction rows

1.6%

795 of 50,023 rows, 8th most common

Filings with a code C row

1.3%

270 of 20,089 filings

Companies

of 2,099 in the sample

Median days, trade to filing

calendar days

446 of the rows are in Table I (non-derivative securities) and 349 in Table II (derivative securities).

Sample: 50,023 transaction rows in 20,089 Form 4 and 4/A filings filed Jul 23 – Oct 21, 2026 by insiders of 2,099 companies with an AlphaScala stock page. Rows are counted as filed; see how the codes are counted.

SEC Form 4 filings as of Oct 21, 2026

Reading code C on a Form 4

Founders and early investors often hold a class of stock that converts into the listed class. Converting Class B shares into Class A is a C transaction: the Class B shares leave in Table II and the Class A shares arrive in Table I, usually at $0 because nothing is paid.

A conversion changes what the insider holds, not whether the insider bought, so it is not a purchase. A C row followed by code S rows on the same filing shows converted shares being sold.

M covers exercises and conversions exempt under Rule 16b-3, such as company awards. C is listed among the SEC’s derivative securities codes for conversions outside that rule.

Code C in real filings

Recent Form 4 lines coded C, chosen from the newest filings in the sample, one company each. Figures are as filed; each links to the filing on sec.gov.

BULLWebull Corp

Filing on sec.gov

Insider: Wang Anquan, Chief Executive Officer
Transaction date: Sep 30, 2026
Filed: Oct 2, 2026
Table: I, non-derivative
Shares: 25,000,000
Price: –
Shares × price: –
Held after: 25,200,000 (indirect)

Wang Anquan (Chief Executive Officer) acquired 25,000,000 shares through the conversion of a derivative security.
Shares held after the transaction: 25,200,000, held indirectly (By Water Castle Az Inc.).
The same filing also reports 1 code C row (25,000,000 derivative securities).
Filed 2 days after the transaction date.

HGTYHagerty, Inc.

Filing on sec.gov

Insider: Hagerty Holding Corp., 10%+ Owner
Transaction date: Sep 9, 2026
Filed: Sep 11, 2026
Table: II, derivative
Units: 9,250,000
Price: –
Shares × price: –
Held after: 157,302,156 (direct)

Hagerty Holding Corp. (10%+ Owner) converted 9,250,000 derivative securities; this is the Table II side of the conversion.
Derivative securities of this kind held after the transaction: 157,302,156, held directly.
The same filing also reports 3 code C rows (12,025,000 shares and derivative securities) and 2 code S rows (10,637,500 shares).
Filed 2 days after the transaction date.

PATHUiPath, Inc.

Filing on sec.gov

Insider: Dines Daniel, CEO and Chairman
Transaction date: Sep 8, 2026
Filed: Sep 9, 2026
Table: I, non-derivative
Shares: 5,000,000
Price: $0.00
Shares × price: –
Held after: 5,000,000 (indirect)

Dines Daniel (CEO and Chairman) acquired 5,000,000 shares through the conversion of a derivative security, at a reported price of $0.
Shares held after the transaction: 5,000,000, held indirectly (See Footnote).
The same filing also reports 2 code J rows (10,000,000 shares) and 1 code C row (5,000,000 derivative securities).
Filed 1 day after the transaction date.

Codes read alongside C

Code M: Exempt exercise or conversion – conversions exempt under Rule 16b-3
Code X: In-the-money exercise – exercises of in-the-money derivatives
Code S: Open market or private sale – sales of converted shares
Code G: Bona fide gift – gifts filed by the same holders

Questions about these codes

How common is code C on Form 4?

In AlphaScala’s sample of 50,023 Form 4 transaction rows filed Jul 23 – Oct 21, 2026, code C made up 1.6% of rows (795) and appeared on 1.3% of filings (270 of 20,089). It was the 8th most common of the 16 codes found.

Is code C a purchase?

No. C is a "conversion of derivative security": one security the insider already holds becomes another, usually with no payment. Purchases are code P.

What is the difference between code C and code M?

M is an "exercise or conversion of derivative security exempted pursuant to Rule 16b-3". C is a "conversion of derivative security" outside that exemption, listed under the SEC’s derivative securities codes.

Why does one conversion appear on two rows?

General Instruction 4(c) has filers report the conversion of a derivative security in Table II, as a disposition of the derivative, and the underlying shares in Table I. Filers usually add a Table I C row for the shares received.

Definition: SEC Form 4, General Instruction 8 (sec.gov). Examples and counts: AlphaScala's copy of SEC EDGAR Form 4 filings. See all 20 Form 4 transaction codes, insider cluster buys and our methodology.

Educational reference only, not investment advice. Insider transactions have many motives and a Form 4 does not record them. See our risk disclaimer.