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Public Comment

GPS Public Comment

GPS | Stock Options has been released in draft format (GPS options DRAFT.pdf) for public comment.  The Certified Equity Professional Institute (CEPI) at Santa Clara University invites individuals and organizations to send written comments on all matters in this draft.



In 2007, the CEPI launched an initiative to provide unbiased, university-based research to address risk assessment and identify best practices for the equity compensation community. The project was titled GPS – or Guidance, Procedures and Systems. Since that time, the CEPI has published six research documents, each addressing a different facet of equity compensation.


The inaugural publication was released in 2007 and was titled “Nonqualified Stock Options”. The original scope included just nonqualified stock options with the intent to be utilized as a resource for companies and stock plan administrators that went beyond the compliance-focused traditional equity compensation administration publication. In 2015, the CEPI initiated an update to the publication and added incentive stock options (ISOs) to the scope.


Public Comment:

GPS | Stock Options is now available in draft format (GPS options DRAFT.pdf) for public comment. The CEPI invites individuals and organizations to comment on any and all aspects of the draft, with special emphasis on the following issues.

  • Does the publication provide a comprehensive and accurate description of the unique aspects of incentive stock options (ISOs)? 
  • Does the publication provide enough differentiation of the controls for ISOs versus nonqualified options?
  • Section 4 has been updated to reflect current technology and service models.  Does the publication effectively address this topic?
  • As the ASC 718 simplification project isn't finalized as an amendment, does the publication address the expected results effectively enough to retain value in the publication after its finalization?
  • Is additional guidance necessary for any of the topics covered in this publication?


Comments are requested from those who agree with this draft as well as from those who do not. Comments are most helpful if they identify the issues or specific paragraph or group of paragraphs to which they relate and clearly explain the issue or question. Those who disagree with provisions of this draft are asked to describe their suggested alternatives, supported by specific reasoning.


Click here to download the GPS options DRAFT.pdf for public comment.


NOTE: The draft publication is a 2,000 KB pdf file.  If you need a different format or are unable to download a pdf, please contact the CEPI at


Comments can be submitted via email to


For questions regarding the public comment process, contact the CEPI at or 408/554-2187.


Public comments will be accepted until February 17, 2016.  The final publication with public comment incorporated will be available in late March 2016.




The original publication was funded by Fidelity Stock Plan Services. This updated version is sponsored by: Bank of America Merrill Lynch, bendystraw, Charles Schwab, E*TRADE, Fidelity Stock Plan Services, Morgan Stanley, Solium, and UBS.