Rule 10b-18 as a safe harbor is "voluntary" not a "must". It reduces liability for issuers in accordance with the four rules. Additionally, the 2013 amendments to the rule require periodic disclosure of all issuer repurchases, regardless of whether the repurchases are effected in accordance with the safe harbor rule.
Rule 10b-18 as a safe harbor is "voluntary" not a "must". It reduces liability for issuers in accordance with the four rules. Additionally, the 2013 amendments to the rule require periodic disclosure of all issuer repurchases, regardless of whether the repurchases are effected in accordance with the safe harbor rule.