News & Analysis as of

10b5-1 Plans Disclosure Requirements Form 10-K

Fenwick & West LLP

SEC updates CDIs on Rule 10b5-1 plans, clawbacks, and de-SPAC transactions

Fenwick & West LLP on

On April 25, the SEC staff added two new Compliance and Disclosure Interpretations (CDIs), revised 20 CDIs and withdrew three CDIs related to 10b5-1 plans. The SEC staff largely revised the CDIs to conform to the 2022 Rule...more

Snell & Wilmer

Corporate Communicator - 2024 Annual Meeting Season

Snell & Wilmer on

Clawback Rules. As previously discussed in last Winter’s Corporate Communicator, the Securities and Exchange Commission (“SEC") adopted final rules in October 2022 directing the NYSE and Nasdaq to adopt listing standards that...more

Snell & Wilmer

2023 End of Year Plan Sponsor “To Do” List (Part 4) Executive Compensation

Snell & Wilmer on

As 2023 comes to an end, we are pleased to present our traditional End of Year Plan Sponsor “To Do” Lists. This year, we present our To Do Lists in four separate SW Benefits Updates. Part 1 covered health and welfare plan...more

Snell & Wilmer

Corporate Communicator - July 2023

Snell & Wilmer on

SEC Enhancement of Share Repurchase Disclosure Requirements - On May 3, 2023, the Securities and Exchange Commission (the “SEC”) announced its adoption of amendments to the provisions of Item 703 of Regulation S-K (“Item...more

Eversheds Sutherland (US) LLP

SEC adopts rules to expand, modernize share repurchase disclosure

On May 3, 2023, the US Securities and Exchange Commission (the SEC) released final rules requiring enhanced disclosure relating to issuers' repurchases of their securities and executives’ trading thereof (the Repurchase...more

Dinsmore & Shohl LLP

Regula Interruptus – Share Repurchase Disclosure Rule Delayed?

Dinsmore & Shohl LLP on

The SEC has published its final rule for the modernization of share repurchase disclosures. The final rule will require additional details of an issuer’s share repurchase activity. Unlike the previous requirements for share...more

Kelley Drye & Warren LLP

SEC Adopts Share Repurchase Disclosure Amendments

On May 3, 2023 the Securities and Exchange Commission (SEC) adopted amendments to modernize the disclosure requirements relating to share repurchases by issuers. The amendments include new tabular disclosures regarding daily...more

Jones Day

SEC Adopts Final Rules Regarding Share Repurchases and Related Disclosures

Jones Day on

On May 3, 2023, the Securities and Exchange Commission adopted final rules regarding public company issuers' share repurchases and Rule 10b5-1 trading plans. Although the final rules are not as burdensome as the proposed...more

Kilpatrick

SEC Adopts New Share Repurchase Disclosure Rules

Kilpatrick on

On May 3, 2023, the Securities and Exchange Commission adopted amendments to modernize the disclosure requirements relating to repurchases of an issuer’s equity securities. The amendments are intended by the SEC to “improve...more

Ballard Spahr LLP

SEC Adopts Amendments Regarding Share Repurchase Disclosure Modernization

Ballard Spahr LLP on

Summary - On May 3, 2022, the Securities and Exchange Commission (SEC) adopted final rules to modernize disclosure requirements relating to the repurchase by issuers of equity securities that are registered under the...more

Cooley LLP

Chamber sues SEC over share repurchase rules

Cooley LLP on

On Friday, the U.S. Chamber of Commerce announced that, together with the Texas Association of Business and the Longview Chamber of Commerce, it had filed litigation in the Fifth Circuit against the SEC to prevent...more

Kramer Levin Naftalis & Frankel LLP

SEC Amends Share Repurchase Disclosure Rules

On May 3, 2023, the Securities and Exchange Commission (SEC) adopted amendments to increase disclosures for issuer repurchases of shares or other equity securities that are registered under Section 12 of the Securities...more

Polsinelli

The SEC's New Disclosure Requirements for Share Repurchases

Polsinelli on

On May 3, 2023, the Securities and Exchange Commission (the “SEC”) adopted new rules and related amendments regarding disclosure of share repurchase programs by corporate issuers and their affiliated purchasers. These...more

McGuireWoods LLP

SEC Adopts Amendments to Modernize Share Repurchase Disclosure

McGuireWoods LLP on

On May 3, 2023, the U.S. Securities and Exchange Commission (SEC), by a vote of 3-2, adopted amendments to modernize the disclosure requirements relating to issuers’ repurchases of their equity securities that are registered...more

Davis Wright Tremaine LLP

SEC Adopts Proposals to Enhance Share Repurchase Disclosures and Private Fund Reporting

On May 3, 2023, the Commission announced that it adopted amendments to two rules enhancing disclosure requirements for share repurchases and private fund reporting. First, the Commission adopted amendments to the rules on...more

Troutman Pepper Locke

SEC Adopts Final Rule Amendments That Increase Disclosures Relating to Share Repurchases

Troutman Pepper Locke on

On May 3, the Securities and Exchange Commission (SEC) adopted rule amendments regarding disclosures about repurchases of an issuer's equity securities, or issuer stock buybacks. The final rule and fact sheet can be found...more

Troutman Pepper Locke

SEC Adopts Revised Stock Buyback Disclosure Requirements

Troutman Pepper Locke on

On May 3, 2023, the SEC adopted final rules relating to corporate stock buybacks. The new rules have some significant differences from those the SEC proposed in December 2021. While the new rules do require significantly...more

Cooley LLP

SEC Final Share Repurchase Disclosure Rules Less Burdensome Than Expected

Cooley LLP on

On May 3, 2023, the Securities and Exchange Commission (SEC) voted at an open meeting to adopt final rules to require enhanced disclosure about issuer share repurchases under the Securities Exchange Act of 1934, as amended....more

Stinson - Corporate & Securities Law Blog

SEC Adopts Final Amendments Related to Share Repurchases

The SEC has adopted final amendments requiring disclosures related to issuers’ share repurchases. The amendments will require domestic issuers to...more

Keating Muething & Klekamp PLL

Securities Snapshot: 1st Quarter 2023 - 2022 Final Rules Now in Effect: What You Need to Know

Securities and Exchange Commission rulemaking continued at a brisk pace in the first quarter of 2023 as the Commission implemented several significant reporting and compliance regulations adopted in 2022. Final rules and...more

Latham & Watkins LLP

Amended Rule 10b5-1 and New Insider Trading Disclosure: Frequently Asked Questions

Latham & Watkins LLP on

Key Points - ..The SEC’s amendments to Rule 10b5-1 and new rules mandating insider trading disclosures take effect at the end of next month. ..The changes raise significant interpretive issues, including ambiguities...more

Mintz - Securities & Capital Markets...

SEC Adopts Amendments to Rule 10b5-1 Insider Trading Arrangements

On December 14, 2022, the Securities and Exchange Commission adopted final rules amending Rule 10b5-1 under the Securities Exchange Act of 1934, as amended, to impose new conditions to the availability of the Rule 10b5-1...more

BCLP

Pulling Back the Curtain - SEC Proposes Expanded Share Repurchase Disclosures

BCLP on

Last week, the Securities and Exchange Commission proposed rule amendments that would enhance issuer disclosures regarding their share repurchase transactions. The proposed rule changes consist of two components,...more

Wyrick Robbins Yates & Ponton LLP

SEC Issues Proposed Rules on Rule 10b5-1 Plans and Insider Trading

On December 15, 2021, the Securities and Exchange Commission (“SEC”) proposed amendments to Rule 10b5-1 under the Securities Exchange Act of 1934 (the “Exchange Act”).  Comments to the proposal are due within 45 days after...more

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