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ARTICLE · 13 DECEMBER 2022

SEC Reopens Share Repurchase Disclosure Modernization Comment Period

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On December 7, 2022, the US Securities and Exchange Commission (SEC) issued a release (New Reopening Release), reopening the comment period on the share repurchase...

United StatesCorporate/Commercial Law
Laura Richman
Laura Richman
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On December 7, 2022, the US Securities and Exchange Commission (SEC) issued a release (New Reopening Release), reopening the comment period on the share repurchase disclosure modernization rule changes that it proposed on December 15, 2021 (Share Repurchase Proposal). At the same time, the SEC made available a memorandum prepared by the staff of the SEC's Division of Economic and Risk Analysis (Staff Memorandum), discussing potential economic effects of the 1% excise tax on certain share repurchases imposed by the Inflation Reduction Act of 2022 (Inflation Reduction Act), that may be helpful in evaluating the Share Repurchase Proposal. The SEC reopened the comment period to allow interested persons to analyze and comment on the Staff Memorandum.

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