74 when revising the disclosure requirement to a quarterly or semi-annual basis, the SEC determined that the buyback disclosure will be considered “filed,” meaning that issuers will be subject to liability for misleading statements under Section 18 of the Exchange Act for this new disclosure, and such information will be incorporated by reference into other filings under the Securities Act of 1933, which are subject to Securities Act Section 11 liability. Machine-Readable Data Language. The Existing Rules do not require that a machine-readable data language be used for buyback disclosures, allowing issuers to use non-machine-readable data languages such as ASCII or HTML. The Amendments require buyback disclosures to be made using a structured, machine-readable data language in Inline XBRL. COMPLIANCE DATES The Amendments become effective 60 days after publication in the Federal Register. However, even though the Amendments will be effective at that time, the SEC provided the following transition periods, allowing additional time before the new disclosures will be required. Except as provided below, issuers will be required to comply with the Amendments on Forms 10-Q and 10-K (for their fourth fiscal quarter), beginning with the first filing that covers the first full fiscal quarter that begins on or after October 1, 2023. For calendar year-end companies, this means the first disclosures will be in the Form 10-K for the year ending December 31, 2023, with such disclosure covering repurchase activities that occurred in the fourth quarter of 2023. FPIs that file on FPI Forms will be required to comply with the Amendments in new Form F-SR, beginning with the Form F-SR that covers the first full fiscal quarter that begins on or after April 1, 2024. The Form 20-F narrative disclosure that relates to the Form F-SR filings will be required starting in the first Form 20-F filed after the FPI’s first Form F-SR has been filed. For calendar year-end companies, this means the first Form F-SR will be required with respect to the second quarter of 2024, which will be due on or before August 14, 2024, and the narrative disclosure will be required in the Form 20-F for the year ending December 31, 2024. Listed Closed-End Funds will be required to comply with the Amendments, beginning with the Form N-CSR that covers the first six-month period that begins on or after January 1, 2024. For calendar year-end companies, this means the first disclosures will be in the Form N-CSR for the semi-annual period ending June 30, 2024.