As we discussed in a prior post, Commissioner Jackson has spoken out on transactions undertaken by public company executives in close proximity to their companies’ stock buybacks.  In his speech, Commissioner Jackson called for public comment on the safe harbor provided by Rule 10b-18 for issuer repurchases.  Recently, a group of senators sent a letter to the Securities and Exchange Commission requesting that the Commission open a public comment period on Rule 10b-18.  That letter may be accessed here.  The letter, like the Commissioner’s comments, appears to conflate the appropriateness of transactions by insiders and the timing of such transactions with the separate issue of stock repurchases conducted in compliance with the safe harbor.  It is not clear why the safe harbor for stock repurchases ought to be related to or conditioned on insider sales/purchases.