SEC Issuer Repurchase Disclosures: Be sure to look at the correct rules
As we discussed in our prior alerts (here, here, and here), the U.S. Court of Appeals for the Fifth Circuit in December 2023, vacated the share repurchase modernization disclosure rules previously approved by the U.S. Securities and Exchange Commission in 2023. This is the rulemaking that would have required new detailed disclosures in Forms 10-K and 10-Q of daily issuer share repurchases, among other things (and similar disclosures for foreign private issuers). Unfortunately, many reference sources that companies use for SEC rules and forms updated them for the modernization disclosure rules but did not further update them to revert back to the preexisting disclosure requirements.
Contributor(s)
Co-Head of Public Company Advisory Group
More from the Governance & Securities Watch
Copyright © 2024 Weil, Gotshal & Manges LLP, All Rights Reserved. The contents of this website may contain attorney advertising under the laws of various states. Prior results do not guarantee a similar outcome. Weil, Gotshal & Manges LLP is headquartered in New York and has office locations in Boston, Brussels, Dallas, Frankfurt, Hong Kong, Houston, London, Los Angeles, Miami, Munich, New York, Paris, San Francisco, Silicon Valley and Washington, D.C.