December 23, 2021
I support the proposed rule to improve share repurchase disclosure through a Form SR. There are a few ways you might consider improving the rule.
This rule provides a single business day for the disclosure of share repurchase activity, which is unnecessary to achieve the desired effect of protecting investors between quarterly reporting periods. Share repurchases, for instance, can be disclosed on a rolling weekly basis, much as quarterly reporting is done on a quarterly basis.
A weekly or monthly system, furthermore, may in practice provide investors with greater signal to noise, allowing for greater and more effective public commentary and analysis of repurchase activity. A periodic system makes it far easier for analysts and journalists to comment on corporate behavior while still greatly expanding market information between quarterly reporting periods.
Finally, reporting on Form SR should also disclose the shares outstanding count for the classes of stock repurchased. If the form only discloses the number of shares repurchased, it is only providing half of the information required to improve corporate disclosure between quarterly reporting periods - the other half is from stock issuance, whether it is to investors or employees.
Regardless of whether disclosure is periodic or continuous, a version of the proposed rule should be implemented.