"On November 10, 2003, the SEC adopted new rules that require companies to disclose all repurchases of equity securities registered under Section 12 of the Securities Exchange Act of 1934 (Exchange Act). These new disclosure requirements apply regardless of whether the repurchases are pursuant to Rule 10b-18 of the Exchange Act or whether they are private or public transactions. All public companies, closed-end mutual funds and foreign private issuers are subject to the new disclosure rules."

http://www.edwardswildman.com/insights/Public...ation=3462