As we discussed in this post, on November 22, 2023, the SEC postponed the effective date of its Share Repurchase Disclosure Modernization rule. The postponement was in the wake of an opinion by the U.S. Court of Appeals for the Fifth District in Chamber of Com. of the USA v SEC. Gary Brown of Nelson Mullins has written this Securities Alert exploring how companies should deal with the postponement, including the implications for issuer 10b5-1 plans.
As always, your thoughts and comments are welcome.