December 16, 2021
Comments attached.
Requiring a rationale for the repurchase would be helpful, but I imagine most companies would simply choose \"because we believe our stock to be undervalued\", \"because it's a good use of our excess cash\", or \"to offset dilution related to employee stock compensation\". It won't really be all that informative.
Daily Reporting is too much - it will create too much \"white noise\" that investors will be overwhelmed. Alternatively, I would suggest a) a filing upon Board approval of the plan (so investors know the company will be repurchasing shares) b) a filing once the first repurchase against a plan was executed (so investors know they started) c) end-of-month reporting on monthly activity (so investors can monitor progress) and d) filing once the plan has been completed with cumulative stats regarding #shares, average purchase price, etc. (so investors know when the company is no longer in the market). This protocol will enhance disclosure but not materially depress a company's ability to take out weak hands via their repurchase activity and will not create an avalanche of daily filings that will overwhelm investors.