On December 19, 2023, the U.S. Court of Appeals for the Fifth Circuit vacated the SEC’s May 3, 2023, share repurchase disclosure rules (Chamber of Com. of the USA v. SEC, No. 23-60255 (5th Cir.).   As a result of this decision, CorpFin issued this Announcement on February 9, 2024, clarifying that companies should follow the pre-amendment disclosure requirements in S-K Item 703 to provide monthly information about share repurchase transactions.  The following example from Proctor and Gamble’s June 30, 2023 Form 10-K follows the prior rules:

Note that this disclosure is included in Item 5 of Form 10-K.

As always, your thoughts and comments are welcome.