June Edition 2023

69 Objectives or rationales for the buyback and process/criteria used to determine repurchase amounts Not required Required Policies and procedures relating to transactions by officers and directors during a buyback program Not required Required Whether buyback was made pursuant to a plan intended to satisfy the Rule 10b5-1(c) affirmative defense Not required Required Whether buyback was intended by the issuer to qualify for the Rule 10b-18 non-exclusive safe harbor Not required Required Disclosure of principal terms of buyback transaction Required by footnote Required narratively in more detail than the Existing Rules II. Timing of Disclosure Disclosure of buyback information Disclose in periodic filings, reported month by month for each month covered by the periodic filing Frequency depends on type of issuer and form used Disclose on a daily basis for each buyback transaction, quarterly or semi-annually depending on type of issuer: • On Forms 10-Q or 10-K for issuers using those forms • On new Form F-SR for FPIs that report on FPI Forms. • On Form N-CSR for Listed Closed-End Funds. III. Mode of Disclosure Machine-readable data language required Issuer can disclose using non-machine readable data languages (e.g., ASCII or HTML). Issuer must use machinereadable data language (Inline XBRL).