The Issuer Repurchase Safe Harbor

What this video covers

• What the safe harbor protects: manipulation liability based solely on the time, price, amount, or number of brokers or dealers used, and why it does not cover fraud or an evasion scheme
• Why compliance is voluntary, why each condition must be met daily, and why one failure removes all repurchases from that day without creating a presumption of violation
• Which purchases count, including common stock, equivalent interests, riskless principal transactions, and unexecuted bids or limit orders, plus the seven exclusions
• How the one-broker condition works, including when a broker that is not an electronic communication network (ECN) or alternative trading system (ATS) may access that liquidity
• How the time condition covers the opening purchase and the or end-of-day blackout in the principal and execution markets
• How the price condition uses the higher of the highest independent bid or last independent transaction price, excluding agent commissions and dealer markups
• How the 25% volume cap, once-weekly block purchase exception, four-week ADTV calculation, six-month principal market lookback, 60-second riskless principal allocation, and 100% ADTV limit after a market-wide suspension fit together