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Securities Administrative Procedure Act

Wilson Sonsini Goodrich & Rosati

SEC Stays Share Repurchase Disclosure Rules

On November 22, 2023, the U.S. Securities and Exchange Commission (SEC) announced that it issued an order postponing the effective date of the share repurchase disclosure rule (Repurchase Rule).[1] The Repurchase Rule was...more

Wilson Sonsini Goodrich & Rosati

Share Repurchase Rules: Fifth Circuit Directs SEC to Correct Defects 

In an opinion issued on October 31, 2023, a three-judge panel of the United States Court of Appeals for the Fifth Circuit found that the U.S. Securities and Exchange Commission (SEC) acted “arbitrarily and capriciously” in...more

Allen Matkins

Court Finds That The SEC Acted Arbitrarily and Capriciously In Adopting Share Repurchase Rule

Allen Matkins on

When the Securities and Exchange Commission proposed to adopt a rule a rule requiring issuers to report day-to-day share repurchase data once a quarter and to disclose the reason why the issuer repurchased shares of its own...more

Stinson - Corporate & Securities Law Blog

Court Rejects Regulation A+ Challenge

The States of Montana and Massachusetts had previously challenged Regulation A+’s preemption of state securities registration and qualification requirements in Tier-2 offerings. The United States Court of Appeals for the...more

K&L Gates LLP

Supreme Court’s Perez Decision Shines the Light on Federal Agencies’ Authority to Use “Interpretations” (Often called Shadow...

K&L Gates LLP on

Over the last three decades, federal agencies have increasingly used “interpretations” to “explain” what a formal regulation means, rather than to go through the more expensive, complicated and slow process of changing the...more

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