Subject: Share Repurchase Disclosure Modernization (File No: S7-21-21)
From: Robert Rutkowski
Affiliation:

Apr. 01, 2022



Gary Gensler, Chair
SEC Headquarters
100 F Street, NE
Washington, DC 20549
(202) 551-2100
chairmanoffice@sec.gov

Vanessa A. Countryman
Secretary, Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-1090
rule-comments@sec.gov, help@sec.gov

Re: Share Repurchase Disclosure Modernization (File No: S7-21-21)

Dear Chairman and Secretary:

AFREF led a letter with thirteen organizational signatories commenting
in support of a rule proposed by the Securities and Exchange Commission
that would significantly increase the transparency of stock buybacks.  A
central component of the proposed rule is daily disclosures of stock
buybacks.  (Current disclosure requirements are only quarterly.)

In the comment letter, they commend the SEC on the proposed rule and
make recommendations to further strengthen protections against market
manipulation and insider trading that would improve long-term financial
stability and growth.

Full letter:
https://ourfinancialsecurity.org/wp-content/uploads/2022/04/4.1.22-corporate-gorvernance-Stock-buybacks-comment-letter-1-1.pdf

Take the time to review these recommendations and give them the weight
they deserve.

Yours sincerely.
Robert E. Rutkowski

cc:
Legislative Correspondence Team
1705 Longworth House Office Building
Washington DC 20515
Office: (202) 225-4131
Fax: (202) 225-4300
keith.abouchar@mail.house.gov

2527 Faxon Court
Topeka, Kansas 66605-2086
P/F: 1 785 379-9671
E-mail: r_e_rutkowski@att.net