SEC proposes major reform of share repurchase disclosure

Hogan Lovells
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On December 15 the SEC proposed new and amended rules that would require most reporting companies to provide more frequent and extensive disclosures about their share repurchase activity. A company engaged in share repurchases would be obligated to report repurchase information on a new Form SR by the end of the first business day following each day on which it executed a repurchase. In addition, in its quarterly share repurchase disclosure, the company would be required to report additional information that would include the purpose or rationale for the repurchases, the criteria the company used to determine the repurchase amounts, and a description of any policies and procedures relating to purchases or sales of the company’s securities by its directors or officers during the repurchase program.

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