ABT

SEC source: 0001179110-17-010300 · edgar.xml · nonDerivative · entry 1

ROUSSEAU MICHAEL T · CIK 0001233677 · Pres., Cardiovas. & Neuromod.

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 183,116

F1 · balance_after: Due to an administrative calculation error, the Form 4 filed on January 6, 2017, underreported the reporting person's ownership by 1 share.

SEC source: 0001179110-17-010183 · edgar.xml · nonDerivative · entry 1

STARKS DANIEL J · CIK 0000902132 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 6,438,704

SEC source: 0001179110-17-010122 · edgar.xml · nonDerivative · entry 1

Ford Robert B · CIK 0001612571 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 52,166

SEC source: 0001179110-17-010133 · edgar.xml · nonDerivative · entry 1

Mason Heather L · CIK 0001432601 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 59,064

SEC source: 0001179110-17-010106 · edgar.xml · derivative · entry 1

TILTON GLENN F · CIK 0001194624 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 30,120

Underlying: Common shares · 678 shares

Expires not disclosed

F1 · derivative.exercise_price: Director fees credited to a stock equivalent unit account under a grantor trust established by the director and paid, in cash, generally at age 65 or upon retirement from the board. The stock equivalent units earn the same return as if the fees were invested in Abbott stock.

F1 · derivative.exercise_date: Director fees credited to a stock equivalent unit account under a grantor trust established by the director and paid, in cash, generally at age 65 or upon retirement from the board. The stock equivalent units earn the same return as if the fees were invested in Abbott stock.

F1 · derivative.expiration_date: Director fees credited to a stock equivalent unit account under a grantor trust established by the director and paid, in cash, generally at age 65 or upon retirement from the board. The stock equivalent units earn the same return as if the fees were invested in Abbott stock.

F2 · balance_after: Balance includes stock equivalent units acquired pursuant to a dividend reinvestment feature.

SEC source: 0001179110-17-010107 · edgar.xml · derivative · entry 1

Alpern Robert J · CIK 0001448074 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 6,320

Underlying: Common shares · 162 shares

Expires not disclosed

F1 · derivative.exercise_price: Director fees credited to a stock equivalent unit account under a grantor trust established by the director and paid, in cash, generally at age 65 or upon retirement from the board. The stock equivalent units earn the same return as if the fees were invested in Abbott stock.

F1 · derivative.exercise_date: Director fees credited to a stock equivalent unit account under a grantor trust established by the director and paid, in cash, generally at age 65 or upon retirement from the board. The stock equivalent units earn the same return as if the fees were invested in Abbott stock.

F1 · derivative.expiration_date: Director fees credited to a stock equivalent unit account under a grantor trust established by the director and paid, in cash, generally at age 65 or upon retirement from the board. The stock equivalent units earn the same return as if the fees were invested in Abbott stock.

F2 · balance_after: Balance includes stock equivalent units acquired pursuant to a dividend reinvestment feature.

SEC source: 0001179110-17-010109 · edgar.xml · nonDerivative · entry 1

LANE ANDREW H · CIK 0001643735 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 0

SEC source: 0001179110-17-010137 · edgar.xml · nonDerivative · entry 1

LANE ANDREW H · CIK 0001643735 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 22,566

F1 · ownership.direct: This Form 4/A correctly reports the reporting person's transaction and beneficial ownership, which was previously reported incorrectly due to a system error.

SEC source: 0001179110-17-009206 · edgar.xml · nonDerivative · entry 4

Watkin Jared · CIK 0001645118 · Senior Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 46,538

SEC source: 0001179110-17-009206 · edgar.xml · nonDerivative · entry 3

Watkin Jared · CIK 0001645118 · Senior Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 46,838

SEC source: 0001179110-17-009206 · edgar.xml · nonDerivative · entry 2

Watkin Jared · CIK 0001645118 · Senior Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 46,990

SEC source: 0001179110-17-009206 · edgar.xml · nonDerivative · entry 1

Watkin Jared · CIK 0001645118 · Senior Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 47,090

SEC source: 0001179110-17-008829 · edgar.xml · derivative · entry 16

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 0

Underlying: Common shares · 44,000 shares

Expires 2022-02-16

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

F4 · security: Employee stock option granted pursuant to the Abbott Laboratories 2009 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-008829 · edgar.xml · derivative · entry 15

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 0

Underlying: Common shares · 45,800 shares

Expires 2021-02-17

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

F4 · security: Employee stock option granted pursuant to the Abbott Laboratories 2009 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-008829 · edgar.xml · derivative · entry 14

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 0

Underlying: Common shares · 28,700 shares

Expires 2020-02-18

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

F4 · security: Employee stock option granted pursuant to the Abbott Laboratories 2009 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-008829 · edgar.xml · derivative · entry 13

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 0

Underlying: Common shares · 38,700 shares

Expires 2019-02-19

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

F3 · security: Employee stock option granted pursuant to the Abbott Laboratories 1996 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-008829 · edgar.xml · derivative · entry 12

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 0

Underlying: Common shares · 39,350 shares

Expires 2018-02-14

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

F3 · security: Employee stock option granted pursuant to the Abbott Laboratories 1996 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 9

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 182,138

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 8

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 377,838

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 7

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 378,138

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 6

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 378,638

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 5

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 378,688

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 4

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 334,688

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 3

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 288,888

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 2

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 260,188

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

SEC source: 0001179110-17-008829 · edgar.xml · nonDerivative · entry 1

Fussell Stephen R · CIK 0001327700 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 221,488

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

SEC source: 0001179110-17-008471 · edgar.xml · nonDerivative · entry 1

YOOR BRIAN B · CIK 0001643528 · Executive Vice President & CFO

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 61,658

SEC source: 0001179110-17-008472 · edgar.xml · nonDerivative · entry 2

LANE ANDREW H · CIK 0001643735 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 22,893

SEC source: 0001179110-17-008472 · edgar.xml · nonDerivative · entry 1

LANE ANDREW H · CIK 0001643735 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 23,495

F1 · shares: Settlement of a performance-based restricted stock unit in shares in a transaction exempt from Section 16(b) under Rule 16b-3.

SEC source: 0001179110-17-008473 · edgar.xml · nonDerivative · entry 1

Ford Robert B · CIK 0001612571 · Executive Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 53,784

SEC source: 0001179110-17-007429 · edgar.xml · derivative · entry 1

Shrimpton Sean · CIK 0001706711 · Senior Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 92,032

Underlying: Common shares · 92,032 shares

Expires 2027-05-14

F1 · security: Employee stock option granted pursuant to the Abbott Laboratories 2017 Incentive Stock Program in a transaction exempt from Section 16 under Rule 16b-3. The option becomes exercisable in annual increments of 30,678 on 5/15/2018, 30,677 on 5/15/2019, and 30,677 on 5/15/2020.

SEC source: 0001179110-17-006400 · edgar.xml · nonDerivative · entry 1

NATH DEEPAK S. · CIK 0001636628 · Senior Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 51,241

SEC source: 0001179110-17-006401 · edgar.xml · nonDerivative · entry 1

Alpern Robert J · CIK 0001448074 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 25,220

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006404 · edgar.xml · nonDerivative · entry 1

Blount Sally E. · CIK 0001537286 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 23,580

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006403 · edgar.xml · derivative · entry 2

AUSTIN ROXANNE S · CIK 0001061632 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 20,852

Underlying: Common shares · 20,852 shares

Expires 2027-04-27

F2 · security: Stock option granted pursuant to the Abbott Laboratories 2017 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-006403 · edgar.xml · nonDerivative · entry 1

AUSTIN ROXANNE S · CIK 0001061632 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 39,727

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006405 · edgar.xml · derivative · entry 2

McKinstry Nancy · CIK 0001294731 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 18,148

Underlying: Common shares · 18,148 shares

Expires 2027-04-27

F2 · security: Stock option granted pursuant to the Abbott Laboratories 2017 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-006405 · edgar.xml · nonDerivative · entry 1

McKinstry Nancy · CIK 0001294731 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 18,480

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006406 · edgar.xml · derivative · entry 2

LIDDY EDWARD M · CIK 0001188983 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 19,890

Underlying: Common shares · 19,890 shares

Expires 2027-04-27

F2 · security: Stock option granted pursuant to the Abbott Laboratories 2017 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-006406 · edgar.xml · nonDerivative · entry 1

LIDDY EDWARD M · CIK 0001188983 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 21,782

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006407 · edgar.xml · derivative · entry 2

NOVAKOVIC PHEBE N · CIK 0001222195 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 19,385

Underlying: Common shares · 19,385 shares

Expires 2027-04-27

F2 · security: Stock option granted pursuant to the Abbott Laboratories 2017 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-006407 · edgar.xml · nonDerivative · entry 1

NOVAKOVIC PHEBE N · CIK 0001222195 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 21,147

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006409 · edgar.xml · derivative · entry 2

OSBORN WILLIAM A · CIK 0001171797 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 21,448

Underlying: Common shares · 21,448 shares

Expires 2027-04-27

F2 · security: Stock option granted pursuant to the Abbott Laboratories 2017 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-006409 · edgar.xml · nonDerivative · entry 1

OSBORN WILLIAM A · CIK 0001171797 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 51,137

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006411 · edgar.xml · derivative · entry 2

SCOTT SAMUEL C III · CIK 0001202862 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 18,148

Underlying: Common shares · 18,148 shares

Expires 2027-04-27

F2 · security: Stock option granted pursuant to the Abbott Laboratories 2017 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.

SEC source: 0001179110-17-006411 · edgar.xml · nonDerivative · entry 1

SCOTT SAMUEL C III · CIK 0001202862 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 34,867

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006412 · edgar.xml · nonDerivative · entry 1

TILTON GLENN F · CIK 0001194624 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 35,867

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

SEC source: 0001179110-17-006413 · edgar.xml · nonDerivative · entry 1

STARKS DANIEL J · CIK 0000902132 · Director

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 6,462,940

F1 · shares: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F1 · price: These are restricted stock units awarded under the Abbott Laboratories 2017 Incentive Stock Program (the "Program"). They will be paid, on a one-to-one basis, in Abbott common shares on the earlier of the date of the director's separation from service, death, or the occurrence of a change in control (as defined in the Program).

F2 · balance_after: Includes a St. Jude Medical, Inc. restricted stock unit award that was converted to an Abbott award of 58,399 restricted stock units in connection with Abbott's acquisition of St. Jude Medical, in a transaction exempt from Section 16 under Rule 16b-3. The restricted stock units are vested and will settle in shares on July 4, 2017.

SEC source: 0001179110-17-006291 · edgar.xml · nonDerivative · entry 1

BIRD ROGER · CIK 0001635313 · Senior Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 51,313

SEC source: 0001179110-17-006289 · edgar.xml · derivative · entry 9

MANNING JOSEPH J · CIK 0001695686 · Senior Vice President

10b5-1 filing: Not disclosed

Ownership: Direct

Disclosed balance after: 0

Underlying: Common shares · 3,200 shares

Expires 2018-02-14

Exercise/conversion can include RSU settlement. Transaction price and option strike are different fields; a missing price is not zero. Derivative and underlying rows can describe the same event.

F1 · security: Employee stock option granted pursuant to the Abbott Laboratories 1996 Incentive Stock Program, in a transaction exempt from Section 16 under Rule 16b-3.