CompoSecure CRO sells 85,365 shares; retains 799,668 shares

Rhea-AI Filing Summary

Amanda "Mandy" Gourbault, Chief Revenue Officer of CompoSecure, Inc. (CMPO), reported an open-market sale of 85,365 shares of Class A Common Stock on 08/13/2025 at a weighted average price of $19.02 per share. After the sale she beneficially owned 799,668 shares on a direct basis. The reported holdings include 218,960 shares currently owned outright and a mix of restricted stock units (RSUs) and performance-vesting RSUs that vest on specified future dates: time-based RSUs vesting through 2032 and 291,670 performance RSUs vesting based on achievement of performance targets. The Form 4 was signed on 08/14/2025 by attorney-in-fact Steven J. Feder.

Positive

• Reporting person retains a substantial stake: 799,668 shares remain beneficially owned after the sale
• Significant long-term alignment: 291,670 performance-vesting RSUs and time-based RSUs vesting through 2032 indicate continued compensation tied to future performance
• Transparent disclosure: Sale price reported as weighted average $19.02 with range provided and willingness to disclose per-price breakdowns

Negative

• Insider sale disclosed: 85,365 shares sold on 08/13/2025 at a weighted average price of $19.02
• Immediate reduction in vested holdings: The sale reduced the reporting person's currently exercisable/owned shares, signaling partial liquidity

Insights

Securities Analyst

TL;DR: Insider sale of 85,365 shares at $19.02 is a material disclosure but leaves the officer with significant remaining ownership.

The reported sale of 85,365 shares on 08/13/2025 at a weighted average price of $19.02 is a clear disposition of equity by a named executive officer. Post-transaction beneficial ownership remains 799,668 shares, which includes both vested shares and a substantial package of time- and performance-based RSUs. From a market-impact perspective, the filing documents an executed sale rather than an option exercise or conversion; it provides precise price range information and preserves transparency by offering to disclose per-price breakdowns on request. The mix of deferred compensation

Corporate Governance Expert

TL;DR: The transaction is routine insider selling, with continued significant vested and unvested holdings tied to future service and performance.

This Form 4 shows an officer-initiated sale of 85,365 Class A shares and documents remaining holdings of 799,668 shares composed of 218,960 owned shares, multiple tranches of time-based RSUs with vesting through 2032, and 291,670 performance-vesting RSUs. The filing discloses vesting schedules and the contingent nature of performance awards, which is helpful for assessing governance and incentive alignment. The officer remains materially invested in the company while also realizing liquidity on a portion of holdings.

SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

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Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

Gourbault Amanda Mandy

(Last) (First) (Middle)

C/O COMPOSECURE, INC.

309 PIERCE STREET

(Street)

SOMERSET NJ 08873

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
CompoSecure, Inc. [ CMPO ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	Chief Revenue Officer

3. Date of Earliest Transaction (Month/Day/Year)
08/13/2025

4. If Amendment, Date of Original Filed (Month/Day/Year)

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
			Code	V	Amount	(A) or (D)	Price
Class A Common Stock	08/13/2025		S		85,365	D	$19.02(1)	799,668(2)(3)	D

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
				Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares

Explanation of Responses:

1. The price reported in Column 4 is the weighted average price. These shares were sold in multiple transactions at prices ranging from $18.90 to $19.32, inclusive. The reporting person undertakes to provide CompoSecure, Inc. (the "Issuer"), any securityholder of the Issuer, or the staff of the Securities and Exchange Commission, upon request, full information regarding the number of shares sold at each separate price within the ranges set forth in this footnote (1) to this Form 4.

2. Includes (A) 218,960 shares of Class A Common Stock owned by the reporting person, inclusive of shares previously purchased by the reporting person under the Company's Employee Stock Purchase Plan, (B) 63,251 shares of Class A Common Stock underlying restricted stock units ("RSUs"), which will vest in three equal installments on February 26, 2028, February 26, 2030 and February 26, 2032, (C) 75,000 shares of Class A Common Stock underlying RSUs which will vest on January 1, 2026, (D) 43,658 shares of Class A Common Stock underlying RSUs which will vest on January 1, 2026, (E) 107,129 shares of Class A Common Stock underlying RSUs which will vest ratably on each of January 1, 2026 and January 1, 2027, and (cont'd in FN3)

3. (con't from FN 2) (F) 291,670 performance-vesting RSUs, which will vest over the applicable performance period based on the achievement of the provided performance targets, as set forth in the respective governing award agreement, subject in each case to the reporting person's continued service as of the applicable vesting date. The RSUs will be settled into Class A Common Stock upon vesting and may be settled net of shares withheld to pay applicable taxes.

Remarks:

	/s/ Amanda Gourbault, by attorney-in-fact Steven J. Feder	08/14/2025
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
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FAQ

What insider transaction did Amanda Gourbault (CMPO) report?

She sold 85,365 shares of Class A Common Stock on 08/13/2025 at a weighted average price of $19.02 per share, as reported on the Form 4.

How many CompoSecure (CMPO) shares does the reporting person own after the sale?

799,668 shares beneficially owned following the reported transaction, on a direct basis.

What portion of the reported holdings are restricted or performance-based?

Includes 63,251 RSUs vesting in installments through 2032, multiple RSU tranches vesting in 2026 and 2027, and 291,670 performance-vesting RSUs subject to achievement of performance targets.

When were the transactions and filing dated?

Transaction date: 08/13/2025; Form 4 signature date: 08/14/2025 (signed by attorney-in-fact Steven J. Feder).

What was the price range for the sold shares?

The Form 4 states the shares were sold in multiple transactions at prices ranging from $18.90 to $19.32; the reported weighted average price is $19.02.