SEC Proposes Amendments to Rule 10b5‑1 and New Rules for Disclosure of Issuer Share Repurchases
December 29, 2021
On December 28, 2021, Cravath prepared a memo for its clients entitled “SEC Proposes Amendments to Rule 10b5‑1 and New Rules for Disclosure of Issuer Share Repurchases,” which reviews the agency’s proposed changes, released on December 15, 2021, to rules governing affirmative defense against insider trading charges and public company disclosure requirements related to share buybacks, including highlighting some potential areas of ambiguity and potential comment in the proposed rules.
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J.D., 1973, New York University School of LawOrder of the Coif, cum laude
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B.S., 1970, University of Virginiawith Honors
- New York
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M.B.A., 1995, Boston Universitywith High Honors
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J.D., 1994, Boston University School of Lawsumma cum laude
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B.A., 1988, Trinity College
- New York
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LL.M., 2013, New York University School of Law
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J.D., 2007, Benjamin N. Cardozo School of LawOrder of the Coif, Dean's Distinguished Scholar, summa cum laude
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B.S., 2003, Cornell University
- New York
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J.D., 2013, Columbia Law SchoolHarlan Fiske Stone Scholar
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B.A., 2010, University of ChicagoGeneral Honors
- New York
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J.D., 2012, Harvard Law Schoolmagna cum laude
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M.A., 2009, University of Pennsylvania
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B.A., 2009, University of PennsylvaniaPhi Beta Kappa, summa cum laude
- New York
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J.D., 1997, Yale Law SchoolCoker Fellow
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B.A., 1993, University of VirginiaHighest Distinction, Echols Scholar, Phi Beta Kappa
- New York
