As we previously blogged about, the Securities and Exchange
Commission (SEC) adopted final rules intended to enhance public company
disclosure regarding share repurchase programs. U.S. public
companies were set to begin complying with the rules starting with
the filing covering the first full fiscal quarter beginning on or
after Oct. 1, 2023 (i.e., the 2024 Form 10-K for calendar year-end
issuers), with a phased-in schedule for foreign private issuers and
certain registered closed-end funds.
The rules became effective on July 31, 2023, but for now, it
appears their implementation is on hold indefinitely.
Updates to Chamber of Commerce Lawsuit
In May 2023, the U.S. Chamber of Commerce, along with the Texas
Association of Business and the Longview Chamber of Commerce, filed
suit against the SEC in the U.S. Court of Appeals for the Fifth
Circuit asking the court to review the SEC's order approving
the final rules, with the goal of preventing their
