ORCL Form 3: Douglas Kehring Reports Direct Shares, 401(k) Units and RSUs

Rhea-AI Filing Summary

Douglas A. Kehring, Executive Vice President and Principal Financial Officer of Oracle Corp (ORCL), filed an initial Form 3 reporting his beneficial ownership. He directly owns 68,592 shares of Oracle common stock and indirectly holds 2,157.514 units through the company 401(k) plan. He also holds unvested restricted stock units totaling 212,... (213,101) RSUs from three prior grants that convert one-for-one to common shares upon settlement and vest in annual installments.

Positive

• Clear disclosure of direct and indirect holdings including 401(k) plan units
• Detailed vesting schedules provided for three RSU grants (2022, 2023, 2024) with one-for-one share conversion

Negative

• None.

Insights

Corporate Governance Expert

TL;DR: Routine officer disclosure showing direct holdings, 401(k) units and multi-year RSU grants; no new transactions reported.

The Form 3 is a standard initial Section 16 filing for an executive officer. It documents 68,592 directly owned shares, 2,157.514 401(k) plan units and three separate unvested RSU grants totaling 62,400, 74,621, and 76,080 units respectively. Each RSU converts to one share at settlement and vests in equal annual installments, indicating compensation is time-based rather than performance-based. The filing was signed under power of attorney on behalf of Kehring.

Securities Compliance Analyst

TL;DR: Filing complies with Section 16 reporting; disclosures are comprehensive and specify vesting schedules and 401(k) treatment.

The report clearly distinguishes direct ownership from indirect holdings via the issuer's 401(k) fund and specifies the grant dates and annual vesting of RSUs from 2022, 2023 and 2024. No derivative transactions or exercised options are reported. The signature block shows a power of attorney was used to file on 10/01/2025 for the 09/22/2025 event date, consistent with timely administrative filing practices.

SEC Form 3

FORM 3

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

INITIAL STATEMENT OF BENEFICIAL OWNERSHIP OF SECURITIES

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

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1. Name and Address of Reporting Person^*

KEHRING DOUGLAS A

(Last) (First) (Middle)

C/O DELPHI ASSET MGMT CORPORATION

200S.VIRGINIA ST., SUITE 625

(Street)

RENO NV 89501

(City) (State) (Zip)

2. Date of Event Requiring Statement (Month/Day/Year)
09/22/2025

3. Issuer Name and Ticker or Trading Symbol
ORACLE CORP [ ORCL ]

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

	Director		10% Owner
X	Officer (give title below)		Other (specify below)
	EVP, Principal Financial Offcr

5. 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 Beneficially Owned
1. Title of Security (Instr. 4)	2. Amount of Securities Beneficially Owned (Instr. 4)	3. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	4. Nature of Indirect Beneficial Ownership (Instr. 5)
Common Stock	68,592	D
Common Stock	2,157.514(1)	I	By 401(k) Plan

Table II - Derivative Securities Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 4)	2. Date Exercisable and Expiration Date (Month/Day/Year)		3. Title and Amount of Securities Underlying Derivative Security (Instr. 4)		4. Conversion or Exercise Price of Derivative Security	5. Ownership Form: Direct (D) or Indirect (I) (Instr. 5)	6. Nature of Indirect Beneficial Ownership (Instr. 5)
	Date Exercisable	Expiration Date	Title	Amount or Number of Shares
Restricted Stock Unit	(2)	(2)	Common Stock	62,400	(3)	D
Restricted Stock Unit	(4)	(4)	Common Stock	74,621	(3)	D
Restricted Stock Unit	(5)	(5)	Common Stock	76,080	(3)	D

Explanation of Responses:

1. Ownership in the Issuer's 401(k) plan is represented by units in the Issuer's common stock fund in the plan rather than shares of common stock.

2. Represents unvested restricted stock units ("RSUs") from a previous grant of 249,597 RSUs granted on September 20, 2022; the RSUs vest in four equal annual installments, beginning on the first anniversary of the date of the grant.

3. Each restricted stock unit represents the right to receive, at settlement, one share of common stock.

4. Represents unvested RSUs from a previous grant of 149,241 RSUs granted on September 15, 2023; the RSUs vest in four equal annual installments, beginning on the first anniversary of the date of the grant.

5. Represents unvested RSUs from a previous grant of 101,439 RSUs granted on September 19, 2024; the RSUs vest in four equal annual installments, beginning on the first anniversary of the date of the grant.

	/s/ Aimee Weast by Aimee Weast, Attorney in Fact for Douglas Kehring (POA filed 10/1/2025)	10/01/2025
	** 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 5 (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

What does Douglas Kehring report on Form 3 for ORCL?

He reports 68,592 shares directly owned, 2,157.514 units held indirectly via the Oracle 401(k) plan, and unvested RSUs of 62,400, 74,621, and 76,080.

How do the restricted stock units (RSUs) convert to ORCL shares?

Each RSU represents the right to receive one share of Oracle common stock at settlement.

When do the RSUs vest for Kehring?

The RSUs from each grant vest in four equal annual installments beginning on the first anniversary of each grant date (grants dated 9/20/2022, 9/15/2023, 9/19/2024).

Does Kehring hold securities indirectly through retirement plans?

Yes. The filing discloses 2,157.514 units held indirectly in the issuer's 401(k) common stock fund.

Who signed the Form 3 filing and when?

The Form 3 was signed by Aimee Weast as Attorney in Fact for Douglas Kehring on 10/01/2025, with an event date of 09/22/2025.