Morgan J. Hayes, Eric T. Juergens, Steven J. Slutzky, Benjamin R. Pedersen and Andrew Hong

Debevoise Discusses Fifth Circuit Decision on Fixing Share Repurchase Rules

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On October 31, 2023, the Fifth Circuit, in Chamber of Commerce of the USA vs. SEC,[1] found that the Securities and Exchange Commission (the “SEC”) violated the Administrative Procedure Act and directed the SEC to “correct the defects” …