FINRA is the ‘authority’ on dividends, but we must also turn to the National Association of Securities Dealers, Inc. (NASD®) because they are the governing authority on ex-dividend dates;
Let’s examine the slightly convoluted process of a dividend more closely;
- Declare Date: Company declares a distribution to shareholders of cash or securities, and specifies the amount, payment date and record date in accordance with Securities and Exchange Commission (SEC) Rule 10b-17 that requires issuers to give notice of dividends and distributions to the NASD no later than 10 days prior to the record date.
- Ex-Dividend Date: This is determined by the Record Date, and is set according to the National Association of Securities Dealers, Inc. (NASD®) Uniform Practice Code (UPC) according to NASDAQ Rule 11140, under one of two methods;
- The first method, under subparagraph(b)(1) of Rule 11140, provides that for dividends or distributions that are less than 25 percent of the value of the subject security, the date designated as the ex-date shall be the second business day preceding the record date.
- The second method, under subparagraph (b)(2) of Rule 11140, provides that for dividends or distributions that are 25 percent or greater of the value of the subject security, the ex-date shall be the first business day following the payable date.
- Record Date: This is the date the company looks at it’s books to ensure payment to shareholders of record.
- Payment Date: This is the date payment is made.
To be entitled to any cash dividend, all you need do is buy before the ex-dividend date, whether during regular trading hours or extended pre-market or after hours trading, and hold overnight. That’s it.
You might want to check out NASD Notice to Members 00-54 regarding the Methods For Determining Ex-Dividend Dates.
Also be sure to check out the FINRA UPC FAQ on Corporate Actions regarding dividends.