MCO Form 4: President of Moody's Analytics disposes of $1.1M in stock

Rhea-AI Filing Summary

Form 4 shows Moody's Analytics President Stephen T. Tulenko executed two open-market sales of MCO common stock on 07/30/2025. The primary trade disposed of 2,120 shares at $511.18 (~$1.08 million in proceeds), while a fractional adjustment of 0.488 shares at $511.87 followed. After these transactions, Tulenko continues to hold 5,558.382 directly owned shares. No derivative activity or 10b5-1 plan indication was disclosed.

Positive

• None.

Negative

• Insider sale: 2,120 shares sold for ~$1.08 M could be perceived as a modest negative signal, though scale is small relative to market cap.

Insights

Securities Analyst

TL;DR Small insider sale (~$1.1 M) by divisional president; ownership remains sizable—signal is modestly negative but not material.

The reported sale equals roughly 27% of Tulenko’s prior direct holdings, yet absolute size is minor relative to Moody’s $94 B market cap. No 10b5-1 checkbox was marked, so trades appear discretionary. Continued ownership of 5,558 shares suggests ongoing alignment. Overall, the filing provides limited insight into company fundamentals and should not materially alter valuation models.

Corporate Governance Expert

TL;DR Routine Form 4; discretionary sale by officer, governance risk unchanged.

Insider sales become red flags when clustered or coupled with adverse news. This isolated transaction lacks such context. Tulenko remains an officer in good standing and still holds over $2.8 M in equity (at the sale price), maintaining incentive alignment. Governance posture therefore stays stable.

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

OMB Number:			3235-0287
Estimated average burden
hours per response:			0.5

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^*

Tulenko Stephen T

(Last) (First) (Middle)

7 WORLD TRADE CENTER

250 GREENWICH STREET

(Street)

NEW YORK NY 10007

(City) (State) (Zip)

2. Issuer Name and Ticker or Trading Symbol
MOODYS CORP /DE/ [ MCO ]

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

	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	President, Moody's Analytics

3. Date of Earliest Transaction (Month/Day/Year)
07/30/2025

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
Common Stock	07/30/2025		S		2,120	D	$511.18	5,558.87	D
Common Stock	07/30/2025		S		0.488	D	$511.87	5,558.382	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:

Remarks:

	Elizabeth McCarroll by power of attorney for Stephen T. Tulenko	07/31/2025
	** 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.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.

FAQ

How many Moody's (MCO) shares did Stephen T. Tulenko sell?

He sold 2,120 common shares on 07/30/2025 at $511.18 per share, plus a fractional 0.488-share adjustment at $511.87.

What is Tulenko's remaining stake in Moody's after the sale?

Following the transactions he directly owns 5,558.382 shares of MCO.

Did the filing indicate use of a Rule 10b5-1 trading plan?

No. The 10b5-1 plan checkbox was not selected, suggesting the trades were discretionary.

Were any derivative securities involved in this Form 4?

No derivative transactions were reported; only common stock sales were disclosed.

Is this insider sale considered material to MCO investors?

Given Moody's large market capitalization, the ~$1.1 M sale is not financially material and is viewed as a routine insider transaction.