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.
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