Survey Results: Rule 10b-18 & Buybacks


1. Does your company conduct share buybacks only if they comply with Rule 10b-18: (Total responses: n=44)
(select only one)
n=34 (77.27%) Yes
n=6 (13.64%) No
n=4 (9.09%) Not sure, it hasn't come up

2. If your company has conducted a buyback outside of Rule 10b-18, does it: (Total responses: n=11)
(select only one)
n=2 (18.18%) Routinely conduct buybacks outside of Rule 10b-18
n=9 (81.82%) Occasionally conduct buybacks outside of Rule 10b-18
n=0 (0.00%) Inadvertently conducted a buyback outside of Rule 10b-18 one time

3. If your company has conducted a buyback outside of Rule 10b-18, did noncompliance involve: (Total responses: n=9)
(select all that apply, may total more than 100%)
n=4 (44.44%) The volume limits
n=0 (0.00%) The timing of repurchases
n=2 (22.22%) The price of repurchases
n=1 (11.11%) Use of more than one broker
n=2 (22.22%) Other


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