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The Case Against Share Repurchases



Jesse M. Fried



Boalt Hall School of Law, U.C. Berkeley



Abstract



Public companies in the U.S. are increasingly using open market repurchases, rather

than dividends, to distribute cash. Two important reasons for this trend have been

identified: (1) the tax system implicitly subsidizes repurchases by taxing dividends more

heavily; and (2) the structure of managers’ options, which reflects financial accounting

considerations, gives managers a personal financial incentive to distribute cash through

repurchases rather than through dividends. However, the overall desirability of this trend

from an efficiency perspective has yet to be carefully examined. This paper systematically

analyzes the economic differences between repurchases and dividends, and concludes that

repurchases are likely to be a less socially desirable means of distributing cash than

dividends. The paper also proposes a new approach to the regulation of repurchases:

requiring firms buying back their stock on the public market to announce their repurchases

in advance. Such a disclosure rule would reduce the efficiency costs associated with the use

of repurchases without interfering with any of their benefits. The paper concludes by

examining the implications of its analysis for the current debates over the proper tax

treatment of dividends and financial accounting treatment of employee options.



JEL Classification: G30, G32, G35

Keywords: Payout policy, stock repurchases, dividends, signaling.









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Preliminary and Incomplete: Do not cite







TABLE OF CONTENTS



I. Introduction



II. Toward Reconsidering the Desirability of Repurchases

A. The Use and Regulation of Share Repurchases

B. Tax and Options - Accounting Explanations for Repurchases

1. The Implicit Tax Subsidy for Repurchases

2. The Options Accounting Bias Toward Repurchases



III. Reconceiving a Repurchase as a Redistribution Coupled to a Dividend

A. The Reconceptualization

B. The Dividend Component of a Repurchase

1. Allocation of Capital

2. Alteration of Leverage

3. Net Dividend Effects of a Repurchase

C. The Redistributional Component of a Repurchase







IV. The Problems with Coupling a Redistribution to a Dividend

A .Managers’ Use of Repurchases to Enrich Themselves

B. Potential Distortions

1. Underinvestment

2. Cash-hoarding

3. Reduced Disclosure



V. Arguments for Repurchases

A. Financial Flexibility

B. Share Value Signaling

C. Transaction Cost Savings

D. Funding Stock Option Plans



VI. The Desirability of Repurchases When Stock Demand Curves Slope Downward

A. The Possibility of Downward Sloping Stock Demand Curves

B. Managers’ Use of Repurchases to Sell at a Higher Price

C. Potential Distortions

1. Underinvestment

2. Cash-hoarding



VII. Inferring the Desirability of Repurchases from the World Around Us

A. Is There Evidence in Favor of Repurchases?

1. Market Reaction to Repurchase Announcement

2. Failure of Corporate Charters to Prohibit Repurchases

B. The Continuing Use of Dividends



VIII. A New Approach to the Regulation of Repurchases

A. The Proposed Approach: Pre-Repurchase Disclosure

B. The Benefits of Pre-Repurchase Disclosure

C. The Costs of Pre-Repurchase Disclosure

D. Implications for Dividend Taxation and Option Accounting Rules



IX. Conclusion









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I. INTRODUCTION



Firms are increasingly using open market share repurchases rather

than dividends to distribute cash. Two important reasons for this trend have

been identified: (i) repurchases are not taxed as heavily as dividends; and (ii)

the design of managers’ options, which reflects accounting considerations,

leads managers to prefer repurchases over dividends. However, little

attention has been given to the question of whether this trend is desirable

from a social (efficiency) perspective. To answer that question, this paper

systematically compares the economic features of repurchases to those of

dividends. The paper shows that repurchases are likely to be a less efficient

mechanism than dividends for distributing cash. In particular, managers’

ability to use repurchases to redistribute value to themselves from public

shareholders is likely to distort managers’ payout, investment, and

disclosure decisions. The paper also shows that each of the efficiency

benefits commonly attributed to repurchases can be achieved by a simpler

and more efficient mechanism (or by a dividend itself). Although

repurchases are likely to be less efficient than dividends, the paper does not

advocate restricting their use. Instead, the paper puts forward a new

approach to regulating open market repurchases: requiring advance

disclosure of repurchases. The paper shows that such a disclosure rule

would reduce the costs associated with repurchases without interfering with

any of their benefits and thus make repurchase a more efficient payout

mechanism. The paper concludes by discussing the implications of its

analysis for the debate over the optimal taxation of dividends and the proper

accounting treatment of employee options. 1

Over the last 20 years, the use of share repurchases to distribute cash

has increased substantially in the U.S., increasing from $1.4 billion in 1980 to

over $200 billion in 1998.2 Almost all of this cash is distributed through open



1 This paper is part of a larger project of mine on share repurchases by public

firms. Earlier work has examined managers’ motives for using the two main types of

public share repurchases – open market repurchases and repurchase tender offers. See

Jesse M. Fried, Open Market Share Repurchases: Signaling or Managerial Opportunism?, 2

THEORETICAL INQUIRIES IN LAW 865 (2001) (examining whether managers use open

market repurchases to signal that the stock is underpriced and concluding that they do

not); Jesse M. Fried, Insider Signaling and Insider Trading with Repurchase Tender Offers, 67

U. CHI. L. REV. 421 (2000) (examining managers= motives in conducting repurchase

tender offers (ARTOs@) and showing that managers= behavior is consistent with the use

of RTOs for insider trading).

2 See Gustavo Grullon & David L. Ikenberry, What Do We Know About Stock

Repurchases?, 13 J. APPLIED CORP. FIN. 31, 33 (2000); Scott Weisbenner, Corporate Share





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market repurchases (AOMRs@), in which the corporation uses a broker to

buy its own stock on the market over an extended period of time.3

Because of their growing importance, share repurchases have

attracted considerable attention from legal commentators and financial

economists.4 Much of the literature has focused on explaining why

managers are increasingly using repurchases rather than dividends to

distribute cash. The main explanation for repurchases= growing popularity

at the expense of dividends is that repurchases receive more favorable tax

treatment at the shareholder level. Another widely-cited explanation is that

the structure of managers’ options, which reflects accounting considerations,

biases managers in favor of repurchases.

Although the literature has sought to identify reasons for the

increasing use of share repurchases, little attention has been paid to the

normative question that is the focus of this paper - whether the increasing

use of share repurchases is, on balance, efficient B that is, whether the use of







Repurchases in the 1990’s: What Role Do Stock Options Play? 1 (working paper, 2000).

More recently, as other countries have begun removing tax and regulatory impediments

to share repurchases, the use of buybacks outside the U.S. has also dramatically

increased. See, e.g., Peter Goldstein, European Concerns Start to Warm Up to Share

Buybacks: Firms Seek Outlets for Cash As Earnings Improve, Interests Rates Decline, Wall St.

J. Eur., June 23, 1998, at 17 (noting that announced European buyback plans increased to

$42.7 billion in 1997 from $14.2 billion in 1996, in response to current and anticipated

liberalizing of share repurchase laws).

3 See Grullon & Ikenberry, supra note, at 33-34. Most of the remaining repurchases

take the form of a repurchase tender offer (―RTO‖), in which the corporation makes a

time-limited offer to purchase a specified number of shares, usually at a premium over

the market price. See generally Jesse M. Fried, Insider Signaling and Insider Trading with

Repurchase Tender Offers, 67 U. Chi. L. Rev. 421 (2000).

4 See, e.g., F.H. Buckley, When the Medium is the Message: Corporate Buybacks as

Signals, 65 IND. L. J. 493, 539 (1990); Robert Comment and Gregg A. Jarrell, The Relative

Signalling Power of Dutch Auction and Fixed Price Self-Tender Offers and Open Market Share

Repurchases, 46 J. FIN. 1243 (1991); Jesse M. Fried, Open Market Share Repurchases:

Signaling or Managerial Opportunism?, 2 THEORETICAL INQUIRIES IN LAW 865 (2001); Jesse

M. Fried, Insider Signaling and Insider Trading with Repurchase Tender Offers, 67 U. CHI. L.

REV. 421 (2000); David Ikenberry, Josef Lakonishok, and Theo Vermaelen, Market

Underreaction to Open Market Share Repurchases, 39 J. FIN. ECON. 181 (1995); Robert M.

Lawless, Stephen P. Ferris, and Bryan Bacon, The Influence of Legal Liability on Corporate

Financial Signaling, 23 J. CORP. LAW 209 (1998); Erik Lie and John J. McConnell, [RA:

insert title] 49 J. FIN. ECON. 161 (1998); R. Richardson Pettit, Yulong Ma, and Jia He, Do

Corporate Managers Circumvent Insider Trading Regulations? The Case of Stock Repurchases,

7 REV. QUANTITATIVE FINANCE AND ACCOUNTING 81 (1996); Nikos Vafeas, Determinants

of the Choice between Alternative Share Repurchase Methods, 12 J. ACCOUNTING, AUDITING &

FINANCE 101 (1997); Theo Vermaelen, Common Stock Repurchases and Market Signalling, 9

J. FIN. ECON. 139 (1981).





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repurchases rather than dividends to distribute cash generates a larger social

pie.

To answer that question, this paper analyzes the inherent economic

differences between repurchases and dividends – that is, those differences

that would remain even if the tax treatment of the two distribution methods

were identical. The paper shows that a share repurchase is economically

identical to, and can be usefully reconceptualized as, a two-part transaction

involving the corporation and all of its shareholders. In the first part of this

hypothetical transaction, ―remaining shareholders‖ (those shareholders who

remain after the repurchase) buy the shares of ―selling shareholders‖ (those

shareholders who sell their shares back to the firm) at the repurchase price. 5

This part of the transaction redistributes value between selling and

remaining shareholders whenever the repurchase price differs from the

actual value of the stock. I call this part of the hypothetical transaction the

―redistributional component.‖ In the second part, the corporation issues a

dividend (to the remaining shareholders). I call this part the ―dividend

component.‖ The reconceptualization makes clear that a share repurchase is,

essentially, a redistribution (between selling and remaining shareholders)

coupled to a dividend. Thus, the economic desirability of using repurchases

rather than dividends to distribute cash turns largely on the economic

desirability of managers being able to couple a redistribution to a dividend.

The paper shows that managers’ ability to couple a redistribution to a

dividend is likely to lead to distortions in managers’ payout, investment, and

disclosure decisions. First, when the actual value of the stock exceeds its

price, managers seeking to profit from the redistributional component of a

repurchase may well have an incentive to repurchase shares with cash that

would be better invested in the firm’s projects (the ―underinvestment

distortion‖). From an efficiency perspective, it would be desirable for

managers to distribute cash if, and only if, the expected return from

additional investment in the firm’s projects is less than the expected return

available to shareholders from investments outside the firm. However, when

managers can use a repurchase to transfer value from selling shareholders,

they will have an incentive to distribute cash that could be more efficiently

invested in the firm whenever the value transferred from selling

shareholders exceeds the value foregone due to the firm’s inability to use

those funds to invest in its high-value projects.

The second distortion arising from managers’ ability to use

repurchases is that managers might have an incentive to inefficiently hoard



5 Of course, shareholders may sell some but not all of their shares during a

repurchase. For ease of exposition, however, I will assume throughout this paper that

the shareholders who sell stock back to the corporation dispose of all of their shares in

the transaction. This assumption does not affect any of the analysis.





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cash rather than distribute it because of the possibility of using the cash later

to transfer value from selling shareholders (the ―cash-hoarding distortion‖).

From an efficiency perspective, it would be desirable for managers to keep a

certain amount of cash on hand to cover unexpected costs or shortfalls in

revenue. However, to the extent managers expect to be able to use a

repurchase to transfer value from public shareholders they will have an

incentive to keep excess cash in the firm.

Third, managers whose firms repurchase shares will be less willing to

disclose information to the market. It is a familiar point in the insider trading

literature that managers who can engage in insider trading have an incentive

to delay disclosure of information in order to maximize their informational

advantage over public shareholders. This distortion, the paper shows, also

can arise when managers are able to use repurchases to transfer value from

public shareholders.

Because managers cannot use dividends to transfer value from

shareholders, the payout, investment, and disclosure distortions associated

with repurchases do not arise from the use of dividends to distribute the

firm’s cash. Share repurchases thus can impose costs that dividends cannot.

But can repurchases offer any unique benefits that cannot otherwise be

provided? If so, these potential benefits could outweigh the potential costs

associated with repurchases and thereby make repurchases a superior

mechanism for distributing cash. The answer, in short, is ―no.‖

The paper considers four economic benefits attributed to repurchases:

that they provide: (1) greater financial flexibility; (2) a mechanism for

credible share-value signaling; (3) a way to lower shareholder transaction

costs; and (4) shares to ―fund‖ employee and managerial option plans. The

paper addresses each of these benefits attributed to share repurchases and

shows that each benefit can be achieved either by a dividend or by another

mechanism that is simpler and more efficient than a repurchase.

The paper also considers the possibility that a repurchase might boost

the stock price through a ―price pressure‖ effect – that is, by removing shares

from the hands of its lowest-valuing shareholders. The paper explains that if

repurchases can be used to boost the stock price solely by changing the

identity of the marginal shareholder, managers will have an incentive to

repurchase shares shortly before selling their own, in order to sell at a higher

price. The use of repurchases for this purpose may, in turn, give rise to the

same under investment and cash-hoarding distortions that can arise when

managers are able to use repurchases to transfer value from selling

shareholders.

After describing the efficiency and distributional effects of

repurchases, the paper considers the markets positive reaction to repurchase

announcements and other empirical regularities to determine if they shed







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any light on their desirability vis-à-vis dividends. The paper first examines

what can be inferred from the fact that stock repurchase announcements

boost the stock price. The paper explains why a positive reaction to

repurchase announcements does not demonstrate that repurchases are

efficient, either ex post or ex ante. And even if repurchases were efficient,

the positive market reaction would not demonstrate that repurchases are a

more efficient distribution mechanism than dividends. The paper then

considers the possible argument that share repurchases are desirable because

corporate charters would otherwise prohibit them. The paper explains that

even if share repurchases were significantly less efficient than dividends, it

might well be in shareholders’ interest that managers distribute cash through

repurchases rather than dividends because of the tax advantage that

repurchases offer shareholders. Thus the failure of corporate charters to

prohibit repurchases cannot be interpreted to mean that share repurchases

are socially desirable. Finally, the paper argues that the continuing and

persistent use of dividends despite their relatively unfavorable tax treatment

suggests that repurchases have considerable economic costs that, in many

cases, are sufficiently large to outweigh their tax benefits.

Although repurchases are likely to be a less efficient payout

mechanism than dividends, this paper does not advocate restricting their

use. Instead, the paper proposes a new approach to the regulation of

repurchases that would reduce their potential efficiency costs without

reducing any of their potential benefits, and thus make repurchases a more

efficient cash-distribution mechanism. Under this approach, firms would be

required to disclose intended repurchases before effecting them. In previous

work I have shown that requiring individual insiders to disclose their

intended trades in advance would substantially reduce insiders= ability to

trade profitably on inside information.6 Requiring firms to disclose in

advance their intended repurchases would also diminish managers= ability

to use repurchases to indirectly trade on inside information and thereby

reduce the resulting investment, payout, and disclosure distortions.7 At the

same time, such a disclosure requirement would not affect repurchases’

ability to provide financial flexibility, signaling, lower transaction costs, and

shares for option plans.

The paper concludes by briefly considering some of the implications

of the analysis for the debates over the optimal taxation of dividends and the





6 See Jesse M. Fried, Reducing the Profitability of Corporate Insider Trading Through

Pretrading Disclosure, 71 S. Cal. L. Rev. 303 (1998).

7 Pre-repurchase disclosure would not be required, however, if the repurchase is

conducted by a person or organization that does not have access to inside information

about the firm, or by the corporation itself according to a disclosed, pre-arranged plan

that is not entered into or cancelled at a time when managers have inside information.





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proper accounting treatment of employee options. There is evidence that the

current tax subsidy provided to repurchases and the absence of dividend

protection in managers’ options are significant factors in the use of

repurchases, and may lead shareholders and managers to prefer repurchases

even though they may well be less efficient than dividends. From an

efficiency perspective, it may well be desirable to reduce or eliminate these

distortions. The tax distortion could be reduced by diminishing the implicit

tax subsidy for repurchases, which in turn could be accomplished either by

increasing the taxation of repurchases or by reducing the taxation of

dividends. The analysis thus suggests an additional argument for recent

proposals to lower the taxation of dividends. The accounting distortion

could be eliminated either by requiring that all employee options including

those without dividend protection, to be expensed, or by not requiring any

employee options, including those with dividend protection, to be expensed.

The analysis thus offers another reason in favor of recent proposals to

expense all employee options.

The remainder of the paper is organized as follows. Part II describes

the increasing importance of repurchases as a payout mechanism, and the

two factors believed to be most responsible for this trend: (1) the implicit tax

subsidy currently accorded repurchases; and (2) the structure of managers’

options compensation, which is likely driven by accounting considerations.

Part III demonstrates that any share repurchase is economically

equivalent to the corporation (1) causing remaining shareholders to buy the

stock of selling shareholders and (2) issuing a dividend. It systematically

analyzes the efficiency benefits and costs of share repurchases that arise from

the dividend component of a repurchase, and shows that the net efficiency

effect of the dividend component could be either positive or negative. It then

explains how the redistributional component transfers value between

remaining and selling shareholders.

Part IV identifies distortions arising from managers’ ability to

repurchase shares. It begins by explaining how managers can use

repurchases to buy stock at a low price and to use repurchase

announcements to boost the stock price before selling their shares. It then

describes the underinvestment, cash hoarding, and reduced disclosure that is

likely to result from the use of repurchases to transfer value to managers

from selling shareholders.

Part V critically examines the four benefits attributed to share

repurchases relative to dividends: (1) greater financial flexibility; (2) credible

share value signaling; (3) lower transaction costs; and (4) ―funding‖ of

employee option plans. It shows that all of these benefits can be achieved as

easily with a dividend and/or simpler and more efficient mechanism than a

repurchase.







-6-

Part VI considers the possibility that stock demand curve slope

downward. If stock demand curves are downward sloping, then managers

can also use repurchases (and not just repurchase announcements) to boost

the stock price before selling their shares. This increases the frequency of the

under-investment and cash-hoarding distortions that, as Part IV explained,

arise when managers use repurchases to buy stock at a low price.

Part VII considers the implications for the desirability of repurchases

of three empirical regularities: that markets react positively to repurchase

announcements, that corporate charters do not place restrictions on

managers’ ability to repurchase shares, and that firms continue to use

dividends despite their tax disadvantage. It explains why the first two

regularities – markets’ positive reactions to share repurchase announcements

and the failure of corporate charters to prohibit repurchases – do not indicate

that repurchases are an efficient mechanism for distributing cash and the

third regularities – the continuing use of dividends is consistent with it being

an inefficient mechanism for distributing cash.

Part VIII puts forward the pre-repurchase disclosure proposal and

shows that requiring firms to announce their repurchases in advance would

make it very difficult for managers to use repurchases to indirectly buy stock

at a low price. This, in turn, would reduce the distortions associated with the

use of repurchases to transfer value from selling shareholders – including

under-investment, cash-hoarding, and reduced disclosure. If stock demand

curves are downward sloping, such pre-repurchase announcements might

also reduce managers’ ability to boost the stock price by having the firm

repurchase shares, and the distortions that result from the use of repurchases

for that purpose. Part VIII also considers the tax and accounting policy

implications of the analysis. Part IX concludes.



II. TOWARD RECONSIDERING THE DESIRABILITY OF REPURCHASES



Section A describes the increasing popularity of share repurchases

and how they are currently regulated. Section B explains the implicit tax

subsidy accorded to repurchases and the accounting rules governing the

expensing of managerial options, both of which are believed to be important

factors behind the increasing use of repurchases rather than dividends to

distribute cash.



A. The Use and Regulation of Share Repurchases



Managers wishing to distribute cash to public shareholders must

either issue a dividend or repurchase shares. Over the last 20 years, the use









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of share repurchases to distribute cash has increased substantially in the U.S.,

increasing from $1.4 billion in 1980 to over $200 billion in 1998.8

The increase in the use of share repurchases appears to be coming, at

least in part, at the expense of dividends.9 The average payout/earnings

ratio for publicly traded US firms has remained fairly constant during the

period 1974-1998, at around 26-28%.10 During this period, the average

payout/earnings ratio for repurchases has increased from 3.7% to 13.6%, and

the average payout/earnings ratio for dividends has declined by an almost

equal amount, from 22.3% to 13.8%. 11

The increase in repurchases is due in part to more firms using

repurchases instead of dividends to distribute cash. The percentage of firms

initiating distributions that initiate distributions using repurchases rather

than dividends has increased from 27% in 1973 to 81% in 1998.12 It is also

due in part to firms that traditionally have payed dividends increasing their

repurchases dramatically while increasing their dividends at a much slower

rate.13 That is, funds that might have been used to increase dividends are

apparently being distributed through repurchases instead.

A share repurchase can take the form of an open market repurchase

(AOMR@), in which the corporation buys back its own stock on the market,

through a broker, or a repurchase tender offer (―RTO‖).14 The focus of this

paper is on OMRs, which are used to purchase approximately _____ $ of



8 See Gustavo Grullon & David L. Ikenberry, What Do We Know About Stock

Repurchases?, 13 J. APPLIED CORP. FIN. 31, 33 (2000); Scott Weisbenner, Corporate Share

Repurchases in the 1990’s: What Role Do Stock Options Play? 1 (working paper, 2000).

9 See, e.g., Gustavo Grullen and Roni Michaely, Dividends, Share Repurchases, and

the Substitution Hypothesis (working paper, 2001).

10 See Grullon and Ikenberry, What do we Know about Stock Repurchases?, J. APPLIED

CORP. FIN. (2000), at 41.

11 See Grullon and Ikenberry, What do we Know about Stock Repurchases?, J. OF

APPLIED CORP. FIN. (2000), at 41. Not all of the reduction in dividends is caused by the

increasing use of repurchases. See Eugene F. Fama and Kenneth R. French, Disappearing

Dividends: Changing Firm Characteristics or Lower Propensity to Pay, 14 J. OF APPLIED CORP.

FIN. 67 (2001) (attributing some of the reduction in dividends to changes in the mix of

publicly traded firms (more small firms with low earnings and high growth rates, which

tend not to distribute cash)). More recently, as other countries have begun removing tax

and regulatory impediments to share repurchases, there has also been a dramatic

increase in the use of buybacks outside the U.S. See, e.g., Peter Goldstein, European

Concerns Start to Warm Up to Share Buybacks: Firms Seek Outlets for Cash As Earnings

Improve, Interests Rates Decline, Wall St. J. Eur., June 23, 1998, at 17 (noting that

announced European buyback plans increased to $42.7 billion in 1997 from $14.2 billion

in 1996, in response to current and anticipated liberalizing of share repurchase laws).

12 See Grullon and Michaely, supra note x.

13 See Grullon and Michaely, supra note x. See also Fama and French, supra note x.

(finding a lower propensity to pay dividends among public firms)

14 See supra note x.





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shares per year, or 90-95% of the total amount of shares repurchased

annually.15

Under the rules of U.S. stock exchanges, firms are required to

announce the establishment of open market buyback programs.16 Such

announcements are usually greeted favorably by the market, and they are

associated with short-term ―abnormal‖ (i.e., market-adjusted) share price

increases averaging 3%-4%.17

However, OMRs are subject to very few disclosure (or other)

requirements. The repurchasing firm need not announce when it begins,

suspends, resumes, and completes its repurchase of shares. If a firm

announces an OMR, it will typically indicate the number of shares it intends

to repurchase,18 but at the same time make clear that the number of shares

that will actually be repurchased will depend on market conditions.19 As

result, the firm is not obligated to repurchase any shares. 20 On average,

OMRs target 7 percent of outstanding shares,21 and companies announcing

OMRs repurchase 70-80 percent of the targeted number of shares.22

However, a substantial number of corporations announcing OMRs never

repurchase a single share.23 Firms conducting OMRs usually complete them

over periods ranging from several months to several years. 24

One reason the use of share repurchases increased so dramatically in

the mid 1980s is that prior to 1983 managers feared that OMRs would subject



15 See Grullon & Ikenberry, supra note, at 33-34.

16 See Matthew J. Gardella, Stock Buybacks: Legal Issues Under the Federal Securities

Laws and Other Practical Considerations, 13 INSIGHTS 2 (1999).

17 See Ikenberry et al., supra note __, at 190 (reporting that the average market

reaction to OMR announcements in all of the OMRs announced between January 1980

and December 1990 by firms listed on the American Stock Exchange, New York Stock

Exchange, and NASDAQ was 3.54%).

18 Approximately 20-30% of firms don’t announce the number of shares they plan

to acquire. See Maxwell and Stephens (reporting that 20% don’t announce), at 6;

Jaganathan & Stephens, supra note x at 6 (reporting that 30% don’t announce).

19 See Ikenberry and Vermaelen, The Option to Repurchase Stock, 25 FIN. MAN. ___

(1996)(conceiving repurchase announcements as an option to repurchase if the stock

becomes underpriced).

20 Some firms announce an intention to undertake open market repurchases

without specifying a dollar amount or time limitation. See Grullon and Ikenberry, p. 33.

21 See Ikenberry, et. al., supra note, at 185 (reporting that the average percentage of

outstanding shares sought in all of the open market repurchases announced between

January 1980 and December 1990 by firms listed on the ASE, NYSE, and NASDAQ was

6.6 percent).

22 See Clifford P. Stephens and Michael S. Weisbach, Actual Share Reacquisitions in

Open-Market Repurchase Programs, 53 J. FIN. 313, 314 (1998).

23 See id.

24 See Stephens and Weisbach, supra note x. In contrast, RTOs, which target twice

as many shares, are completed within one month. See Fried, supra note x.





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them to liability for violating the anti-manipulation provisions of Section

9(a)(2) of the 1934 Act.25 However, in 1982, the SEC adopted a safe harbor

provision from anti-manipulation liability, Rule 10b-18,26 which provides

repurchasing firms a Asafe harbor@ from anti-manipulation liability under

Section 9(a)(2).27 The rule went into effect in 1983. Among other things, Rule

10b-18 requires a firm seeking the safe harbor to (1) limit the number of

shares it purchases on the open market each day to 25 percent of the average

daily trading volume of the previous month and (2) not offer a price that is

higher than the last sale price on the exchange or the current bid quote,

whichever is higher.28

Interestingly, most corporations fail to comply exactly with the

provisions of the Rule 10b-18 safe harbor.29 However, they tend to sharply

limit the number of shares repurchased per day in keeping with the ―spirit‖

of the rule.30



B. Tax and Options-Accounting Explanations for Repurchases



We now turn to the leading explanations for the increasing use of

repurchases: (1) their favorable tax treatment relative to dividends and (2)

the accounting treatment of managers’ options. Before proceeding to

consider each of these explanations in more detail, it is worth noting that





25 See Grullon and Michaely, supra note x at 5 (reporting that the amount of

repurchases had tripled one year after Rule 10b-18 was put in effect).

26 See 17 C.F.R. 240.10b-18 (1999).

27 Under Section 9(a)(2), it is illegal to conduct a series of transactions creating

actual or apparent active trading in a security, for the purpose of inducing the purchase

or sale of the security.

In releasing Rule 10b-18 the SEC made clear that it does not provide a safe

harbor from Rule 10b-5 liability. Sec. Ex. Act. Rel. 19,244 26 SEC Dock. 868, 869 n.5

(1982). Thus the issuer is not permitted to repurchase while in possession of favorable,

material, nonpublic information concerning its securities.

28 Other requirements are that open market purchases must be made through (a)

only one broker (per day); (b) at a time other than the last half hour of trading and (c)

after the opening transaction. Another legal risk facing the firm is that the OMR might

be considered a constructive repurchase tender offer, subjecting the firm to all of the

restrictions on RTOs described in Fried, supra note x. There is no safe harbor analogous

to Rule 10b-18 from liability resulting from a constructive tender offer. However,

because of the restrictions on price and volume, buybacks conducted under Rule 10b-18

are also not likely to be considered a "tender offer" for the purposes of the securities

laws. Edward Herlihy, et al., Financial Institutions Mergers and Acquisitions 393

(PRACTICING LAW INSTITUTE CORPORATE LAW AND PRACTICE HANDBOOK SERIES No. B4-

7179) (1997).

29 See, e.g., Krigman, Cook ___________.

30 Id.





- 10 -

these two explanations for the increasing use of share repurchases have

nothing to do with the efficiency of share repurchases relative to that of

dividends. Thus, the fact that repurchases have become so popular does not,

by itself, provide evidence that share repurchases are more efficient than

dividends.



1. The Implicit Tax Subsidy for Repurchases



An important reason for repurchases’ popularity is that, under current

tax rules, they are taxed less heavily than dividends. 31

When the firm issues a dividend, all taxable shareholders are taxed at

ordinary income rates on the amount of dividend they receive. In contrast,

when the firm repurchases shares, only those shareholders who choose to

sell their shares are taxed. In addition, those selling shareholders are taxed at

the capital gains rate, which in most cases is less than the ordinary income

rate to which dividends are subject. Finally, these selling shareholders are

not taxed on the full amount of the sale proceeds, but rather only on the

difference between the sale proceeds and the shareholders’ cost basis in the

stock.

Consider a taxable shareholder who owns shares of ABC Corp. in a

taxable brokerage account. When ABC Corp. issues dividends, the

shareholder has taxable income equal to 100% of the dividends he receives.

That income is taxed at the rate at which ordinary income is taxed. Thus if

the shareholder receives $100 in dividends he must pay tax on those

dividends at his marginal combined federal and state income tax rate. If his

marginal combined rate is 40%,32 the shareholder receiving the $100

dividend must pay $40 in taxes, leaving him with $60.

When ABC Corp. repurchases shares, the tax burden on the

shareholder is much lighter. If the shareholder chooses not to sell any of his





31 See Eugene F. Fama and Kenneth R. French, Disappearing Dividends: Changing

Firm Characteristics or Lower Propensity to Pay, 14 J. APPLIED CORPORATE FINANCE 67

(2001) (claiming that the decline in propensity among firms to pay dividends is due to

tax reasons). For evidence that the decision to repurchase shares rather than issue

dividends is partially tax-driven, see Indudeep S. Chhachhi & Wallace N. Davidson III,

A Comparison of the Market Reaction to Specially Designated Dividends and Tender Offer Stock

Repurchases, 26 FIN. MGMT. 89, 93-94 (1997). See also Grullon and Michaely

(2000)(finding that market reaction to a repurchase announcement are higher when the

expected tax benefits are higher); Erik Lie and Heidi Lie, The Role of Personal Taxes in

Corporate Decisions: An Empirical Analysis of Share Repurchases and Dividends, 34 J. FIN.

QUANTITATIVE ANALYSIS ___ (1999) (finding . . . ) [RA: complete cite].



32 The top marginal federal tax rate on ordinary income is ____ (as of December

2002).





- 11 -

shares, he has no taxable income and accordingly pays no taxes. If, on the

other hand, the shareholder sells his shares, he has taxable income only to

the extent that the sale price exceeds his cost basis in the stock. In addition,

that income would be taxed at the capital gains rate, which is often more

favorable than the tax rate for ordinary income.

Suppose, for example, that the shareholder sells to ABC Co. or another

buyer in the market $100 worth of ABC stock that he had purchased for $20.

The shareholder would be taxed only on the difference between the sale

price ($100) and his cost ($20), which is $80. Suppose that the marginal

combined federal and state tax rate for these capital gains is 25%. 33 In that

case, the shareholder would pay only $20 in taxes, leaving him with $80 ($20

more than if ABC Corp. had issued $100 of dividends to the shareholder).

Thus the tax system effectively provides a subsidy to share repurchases.34





2. The Options Accounting Bias Towards Repurchases



Another widely accepted reason for the increasing use of repurchases

rather than dividends lies in the historic accounting treatment accorded

different types of employee stock options. Currently, firms need not take an

accounting charge against reported earnings when they issue employee

options whose strike price is fixed at or above the grant-date market price.

However, the firms must take a charge against earnings when they issue

employee options whose strike price could change over time. Thus, almost

every public firm gives managers fixed-price options.

The value of managers= fixed-price options is in large part based on

the difference between the current stock price and the fixed exercise price.

The stock price, in turn, reflects the per share value of the firm (the total

value of the firm divided by the number of outstanding shares). Thus, a

reduction in per share value of the firm reduces the stock price, which in

turn reduces the value of managers’ options.

A dividend will tend to reduce the value of manager’s options. By

removing cash from the firm, the dividend reduces the total value of the

firm, without reducing the number of outstanding shares. This reduces per

share value and, in turn, the stock price. And a lower stock price makes

managers= options less valuable.

A share repurchase also removes cash from the firm, reducing the

total value of the firm. However, the repurchase also reduces the number of

outstanding shares. Thus, a repurchase does not reduce per share value if the

reduction in the firm=s value is offset by the reduction in the number of



33 The top federal marginal rate on long-term gains is _____ (as of ___________).

34 See Amy K. Dittmar, Why Do Firms Repurchase Stock?, 73 J. BUS. 331, 334 (2000).





- 12 -

shares outstanding. As a result, distributing the cash through a repurchase

does not necessarily lead to a reduction in per share value and the stock

price. In fact, if managers can have the firm buy back stock at a price below

its actual value, a repurchase will increase per share value and thereby boost

the stock price. For example, if the firm distributes 10% of its value and buys

back 10% of its shares, per share value and the stock price should remain

unchanged (everything else being equal).35 But, if the firm could buy back

10% of its shares by distributing 8% of its value, a repurchase could increase

per share value, the stock price, and therefore the value of managerial

options. Thus, unlike dividends, repurchases do not necessarily reduce the

value of managerial options, and could in fact increase them.

Because of the asymmetrical effects of dividends and repurchases on

the value of fixed-price options, most option-compensated managers are

personally better off using repurchases rather than dividends to distribute

cash. And, as the use of options in executive compensation has dramatically

increased over the last 20 years, so has the incentive to repurchase shares

rather than issue dividends.36 There is evidence that the increasing use of

repurchases is in fact driven, at least in part, by the increasing use of

options.37

To be sure, one could eliminate the asymmetric effect of dividends

and repurchases on managerial options. In particular, one could protect the

value of managerial options from dividends by reducing the option’s

exercise price by the amount of any dividend. Such ―dividend-protection‖

would eliminate the distortion in favor of repurchases arising from the

existing structure of managerial options. However, dividend protection

would make the exercise price variable and therefore force the firm to

expense managers’ options on its income statement. This in turn would

reduce accounting earnings, which might affect the stock price or perhaps

draw unwanted attention to the value of the options issued to managers.38









35 In Parts III and IV we will see how a repurchase can increase or decrease the

total amount of value available to shareholders and thereby affect per share value.

36 See George W. Fenn & Nellie Liang, Corporate Payout Policy and Managerial Stock

Incentives (Fed. Reserve Sys., Fin. & Econ. Discussion Series Paper No. 1999-23, Mar.

2000); Christine Jolls, Stock Repurchases and Incentive Compensation (NBER Working Paper

No. 6467, 1998).

37 See Kathleen M. Kahle, When a Buyback isn’t a Buyback: Open Market Repurchases

and Employee Options (working paper, 2001)(finding that the decision to repurchase

shares is affected by the number of managerial options outstanding); Fenn and Lang,

supra note x; Jolls, supra note x.

38 See Bebchuk, Fried and Walker, Managerial Power and Rent Extraction in the

Design of Executive Compensation, 69 U. CHI. L. REV. 751 (2002).





- 13 -

Thus, 99% of firms using stock option plans do not dividend-protect the

options.39

An alternative explanation for the lack of dividend protection relates

to the tax efficiency of repurchases: shareholders (acting through the board)

might be attempting, by depriving managers of dividend protection, to give

managers an incentive to repurchase shares rather than issue dividends. If

this were true, then there would be only a single reason for the increasing

use of share repurchases: the tax system. In any event, there is evidence that

the lack of dividend protection in options does create a bias in favor of

repurchases.40





III. Reconceiving a Repurchase as a Redistribution Coupled to a

Dividend



Section A puts forward a reconceptualization of a repurchase as a

redistribution coupled to a dividend. Section B examines the dividend

component of a repurchase and its potential efficiency benefits and costs.

Section C considers the effects of the redistributional component.



A. The Reconcepualization



The paper now puts forward a reconceptualization of a share

repurchase that will help make salient the economic differences between a

repurchase and a dividend. As this Section will show, a share repurchase

can be reconceptualized as a three-part transaction involving trading among

shareholders, a dividend, and a reverse stock split. In particular, a

repurchase is identical in effect to a three-step transaction in which the

corporation (1) causes nonselling shareholders to purchase the stock of

selling shareholders41 at the repurchase price; (2) issues a dividend equal to

the amount of the repurchase; and (3) effects a reverse stock split.42

A diagram can be used to illustrate the equivalence between a share

repurchase and this three-step transaction.



39 See Kevin Murphy, Executive Compensation, in Handbook of Labor Economics (O.

Ashenfelter & D. Card, eds.) (1998).

40 Bartov, Krinsky and Lee, supra note x (cited in Kahle) find that the presence of

dividend protection affects managers’ decision whether to repurchase shares or issue a

dividend.

41 By ―selling shareholders,‖ I mean those selling shareholders whose shares are

purchased by the repurchasing firm.

42 For now, I ignore transaction costs, which would be lower under a repurchase

than under the threestep transaction described here. I will address this potential

advantage of repurchases in Part V.C.





- 14 -

Repurchase = Shareholder Exchange + Dividend + Reverse Stock

Split





Corp XYZ Corp XYZ Corp XYZ Corp XYZ

= + +





1 share $100 $100 2 shares 1 new

share





1 share



A B A B A A

1 share 1 share $100 2 shares



Result

 A owns 1 share giving it 100%

ownership of Corp. XYZ after

XYZ distributes $100

 B gets $100





Suppose that XYZ Corp. has 2 shareholders, A and B, each of whom

owns one share. The figure to the left of the ―=‖ shows a stock repurchase in

which XYZ repurchases B’s share for $100. The effect of the repurchase is

that (1) B has sold his share for $100; (2) XYZ has distributed $100 in cash;

and (3) A owns XYZ’s single share (100% of XYZ’s equity).

The figures to the right of the ―=‖ show a three-step transaction: First,

A buys B’s share for $100. Second, XYZ distributes a dividend of $100 to A

(to reimburse A for his purchase of B’s share). Third, XYZ effects a reverse

stock split by converting A’s 2 existing shares into 1 new share.

It is easy to see that the results of this three-step transaction are

identical to those of the single-step transaction on the right: (1) B ends up

with $100 and no shares in XYZ; (2) XYZ has distributed $100 in cash; and (3)

A owns XYZ’s single share (100% of XYZ’s equity).

Because the reverse stock split is merely a nominal change with no

economic significance, for purposes of the analysis we need to focus only on

the first two steps of this three-step transaction: (1) the redistributional

component (in which nonselling shareholders buy the stock of selling

shareholders) and (2) the dividend component. Because of the economic

equivalence between a share repurchase and these two steps of the

transaction, a share repurchase can be conceived as having two types of

economic effects: the economic effects that flow from the dividend

component of the transaction and the economic effects that flow from the

redistributional component of the transaction. Reconceptualizing a share

repurchase=s effects in this way makes it clear that the only economic

differences between a dividend and a share repurchase are those that arise as





- 15 -

a result of adding the redistributional component. In the next several Parts,

we will see that coupling a redistribution to a dividend can give rise to a

variety of distortions, without providing any unique benefits.

Before we consider these differences, however, it will be useful to first

examine the potential efficiency consequences of a dividend -- and therefore

the potential efficiency consequences arising from the dividend component

of a repurchase. We now turn to this subject.



B. The Dividend Component of a Repurchase



As Section A explained, a share repurchase can be reconceptualized as

a redistributional transaction (the remaining shareholders’ purchase of

shares from departing shareholders at the repurchase price) coupled to a

dividend (a pro-rata distribution of cash).

The purpose of this Part is to highlight an important point for the

analysis of the efficiency benefits and costs of repurchases that will follow:

that the dividend component of a repurchase (by itself) can either reduce or

increase social value. To that end, this Section shows that the dividend

component of a repurchase can generate both efficiency benefits and

efficiency costs.

As we will see, the dividend components generates efficiency benefits

and efficiency costs primarily through two mechanisms. First, the dividend

makes capital that would have been used by the firm available to

shareholders for investment outside the firm. Second, the dividend increases

leverage, which in turn can alter managerial incentives, particularly those

relating to managerial effort levels and project choice. As we will see, there

could be efficiency costs or efficiency benefits associated with each of these

effects -- the reallocation of capital and the alteration of managerial

incentives. Thus, the dividend component of the repurchase can either

increase or decrease social value, depending on the direction and magnitude

of these various efficiency effects. The fact that the social value of the

dividend component could be negative or positive is important because -- as

Part IV explains -- one of the potential costs associated with the coupling of

the redistributional component to the dividend component is that it might

induce managers to conduct repurchases whose dividend-component

reduces social value or induce managers to forego a repurchase whose

dividend component increases social value.

I first examine the capital-reallocation effect of the dividend

component. I then consider the impact of the dividend component on

managerial incentives through its effect on the firm’s leverage. Finally, I

explain how the net effect of the dividend component on social value could

be either positive or negative.







- 16 -

1. Reallocation of Capital



The first mechanism by which a repurchase’s dividend component

can affect social value is through its effect on the allocation of capital. Every

potential investment has an expected return. The expected returns from the

firm’s projects may well differ from the expected returns from other

investments available to the firm’s shareholders. 43 Thus, the dividend

component of a repurchase can affect social value by shifting cash from the

firm’s projects to investments outside the firm. 44

When the firm=s projects have lower expected returns than projects

outside the firm, distributing cash is value increasing.45 Funds that would

generate higher returns outside of the corporation are often called ―excess‖

(or ―free‖) cash. 46 In the U.S., there is evidence that firms use both dividends

and the dividend component of share repurchases to distribute excess cash.47

When a firm=s projects have higher expected returns than the

alternative investments available to its own shareholders, distributing cash is

value-wasting. Call the funds that could be better used in the firm

Aneeded@ cash.



2. Increase in Leverage



The second mechanism by which a repurchase’s dividend component

can affect social value is by altering managerial incentives. In particular, the



43 Managers may not have an incentive to pursue the best projects available to the

firm if the private benefits available from alternative investments (such as a new

corporate jet or fancy office building) are sufficiently high. Thus the social value created

or destroyed by moving funds from corporate to non-corporate projects depends on the

actual projects foregone by the repurchase, and not necessarily the best project available

to the firm. It should also be noted that the cash distributed can also be used for

consumption. The assumption that the cash distributed is used for investment is made

to facilitate the exposition and does not affect any of the analysis.

44 A repurchase moves funds from corporate to noncorporate projects only to the

extent it is not funded with debt incurred for that purpose. To the extent the repurchase

is financed with such debt, the amount of funds available for projects in and outside the

corporation is not affected. However, even if the firm finances the repurchase entirely

out of funds borrowed for that purpose, the repurchase and borrowing would still

increase leverage, the second mechanism through which the repurchase’s dividend

component generates efficiency costs and benefits. See infra Part III.B.2.

45 In determining whether the cash distribution is value increasing, one would also

need to take into account the effect of the distribution on the expected costs associated

with financial distress.

46 See, e.g., Michael Jensen, Agency Costs of Free Cash Flow, Corporation Finance and

Takeovers, 76 AMERICAN ECON. REV. 323 (1986).

47 See Dittmar, at 333-335. See Grullon and Ikenberry, supra note x, p. 40.





- 17 -

dividend component increases leverage, which in turn alters managers’

incentives to (1) exert effort and (2) choose one project over another.

From an efficiency perspective, it would be desirable for managers to

run firms in a way that maximizes social value. In such a world, managers

would choose projects that maximize total wealth. And they would exert an

amount of effort such that the marginal social benefit of additional effort

equals the marginal social cost (including the cost to them personally).48

As is well understood, however, managers= incentives are not fully

aligned with value maximization. Two types of distortions are relevant for

our purposes. First, managers do not capture the full benefit of their efforts

because they own only a fraction of the equity, and thus have an incentive to

work less than would be socially optimal, that is to Ashirk@. Second, to the

extent managers are risk averse, they may forego positive expected value

projects with a high likelihood of failure in favor of lower value projects with

a lower likelihood of failure. The reduction in social value that results from

each of these distortions is called an Aagency cost.@49

As I explain, the magnitude of these effort and project-choice

distortions and the resulting agency costs are affected by the likelihood of

failure. That likelihood is in turn is affected by the firm’s leverage – its

debt/equity ratio.50 The repurchase’s dividend component inevitably

increases the firm’s leverage. Thus, the dividend component affects the

likelihood of failure and, indirectly, managers’ effort and project choice.

The manner in which the dividend component increases the risk of

failure depends on how the repurchase is funded. If the dividend is funded

with new debt, the firm is obligated to make additional interest payments,

which increases the likelihood that the firm will not be able to make these

payments in bad times. If the dividend is not funded with new debt, the

managers will have fewer assets with which to make payments on any old

debt. In either case the likelihood of failure increases. 51 As explained below,



48 More precisely, they would choose a (projects, effort level) combination that

maximizes social value.

49 There is a third type of distortion that can arise. In particular, to the extent that

(a) value can be transferred from creditors to equityholders and (b) managers represent

the interests of equityholders, managers may have an incentive to (1) undertake higher-

risk, lower value projects or (2) distribute needed cash (by a repurchase or dividend) in

order to transfer value from creditors to equityholders. This distortion is similar to the

distortion caused by risk aversion – except in the opposite direction.

50 See, Dittmar, supra note x at 335. See Grullon and Ikenberry, supra note x

(suggesting that firms repurchase shares to offset reduction in leverage caused by

issuing shares to employees.) Cf. Armen Hovakimian, The Role of Target Leverage in

Security Issues and Repurchases (working paper, 2001) (concluding that firms do not

conduct equity repurchases for the purpose of changing their leverage).

51 Another cost of increasing leverage is that is increases the expected costs





- 18 -

by increasing leverage and the risk of failure, the dividend component of a

repurchase can mitigate or exacerbate each of the two distortions described

above.



a. Effect on Managerial Shirking



Managers have an incentive to work less and take less care than is

optimal because they enjoy 100% of the benefit of their Ashirking@ but pay

(through the reduction in the value of their shares) only a small fraction of

the cost of their shirking to the firm.

In theory, shareholders could monitor managers and adjust the salary

of, or even terminate, managers they find to be shirking. Were such

monitoring effective, it would deter shirking. But in practice, it will be

difficult to determine whether a particular manager is shirking (and if so, to

what extent). Furthermore, the transaction costs involved in replacing

management through a proxy contest are very high.52 Thus, even if

shareholders could more easily detect shirking they would have an incentive

to punish managers only in an extreme case.53 Because most shirking is

either unobservable or observable but unpunishable, managers will not be

deterred from shirking, and the reduction in shareholder value that results

from shirking could be significant.

The dividend component should reduce shirking by raising the cost to

the managers of shirking. Specifically, the distribution increases the cost of

shirking by making shirking more likely to lead to the firm not being able to

pay its debts -- a crisis that could threaten managers= jobs. The increased

likelihood of failure should give managers an incentive to focus harder on

generating revenues and cutting costs, making the corporation more

efficient.54 Thus, the dividend component of a repurchase should provide an

efficiency benefit by reducing managerial shirking.



b. Effect on Project Choice



In addition to the incentive to shirk, managers may have an incentive

to forego high-risk projects in favor of lower-risk lower-return projects.

Managers tend to place a high value on keeping their jobs – because of the



associated with financial distress and bankruptcy. See supra note x (discussing this point

in Part III.A.)

52 See Bebchuk and Kahan, A Framework for Analyzing Proxy Contests, __CAL. L.

REV. ___(1990).

53 In an extreme case the managers may also face a hostile takeover bid.

54 Shirking will also be reduced if new debt is incurred and the new creditors are

better suited for monitoring managers than the existing shareholders. See Buckley,

supra note x, at _____.





- 19 -

salary, perquisites, power, and prestige that come with high level positions

in public firms. To the extent a high-risk project increases the likelihood that

the firm will fail (or at least do poorly), that project increases the chance that

managers will lose these valuable jobs. Thus, to managers the expected

costs of initiating a high-risk, high return project may appear extremely high

– and may outweigh whatever benefits the managers expect to get from the

project qua shareholders.

Because the dividend component of a repurchase increases the

likelihood of failure, either form of cash distribution could exacerbate the

problem of risk aversion by making managers even less likely to undertake

value-increasing projects that happen to be risky.



3. Net Dividend Effects of a Repurchase



This Section has considered the efficiency effects of the dividend

component of a repurchase. As we have seen, the dividend component

affects social value through its effects on (1) the allocation of capital, (2)

managerial effort (which is likely to be positive); and (3) project choice

(which is not likely to be positive).

Whether or not the dividend component of a particular share

repurchase increases social value will depend on the directions and relative

strengths of the various effects. For example, the dividend component of a

repurchase might distribute excess cash but worsen managerial incentives

(on balance). In such a case, the net effect on social value depends on

whether the increase in value that results from distributing excess cash

outweighs the decrease in value resulting from the worsened incentives.

For purposes of this paper, however, the direction and relative

magnitude of these various effects is not important. What is important is

that the dividend component of a repurchase can either increase or reduce

social value.





C. THE REDISTRIBUTIONAL COMPONENT OF A REPURCHASE







Having examined the efficiency consequences of the dividend

component of a repurchase, we now turn to consider in more detail the

redistributional effect of a repurchase on remaining shareholders. I first

examine the situation in which the actual value of the stock is the same as the

repurchase price. I then consider both the situation in which the stock’s

actual value is lower than the repurchase price and that in which it is higher.









- 20 -

To focus on the redistributional aspect of a repurchase, I will assume

in this Part that the dividend component of the repurchase has no efficiency

effects. In the next Part, I examine the interaction between the dividend and

redistributional effects of a repurchase when the dividend component does

have efficiency effects. There I will show that the redistributional effects of a

share repurchase can lead managers to conduct a repurchase where the

dividend component is value-decreasing or cause managers to forego a

repurchase when the dividend component would be value-increasing.





1. Effect when Repurchase Price Equals Stock’s Actual Value



We first consider the redistributional effect of a repurchase when the

actual value of the stock equals the repurchase price. As Section A

explained, a repurchase is equivalent to (1) the remaining shareholders

purchasing the shares of departing shareholders at the repurchase price and

(2) the firm issuing a dividend to remaining shareholders. When the actual

value of the shares is the same as the repurchase price, the ―purchase‖ of the

share does not transfer value between the remaining shareholders and the

departing.

A simple example can be used to illustrate this point.









Corp XYZ = Corp XYZ + Corp XYZ

$200 $100 $200 $200 $100





1 share $100 $100



$100

A B A B A

1 share 1 share 1 share 2 shares

worth $100

Result



 A gets 100% of Corp.

XYZ (worth $100)

 B gets $100









- 21 -

Suppose again that XYZ Corp. has 2 shareholders, A and B, each of

whom owns one share. Now suppose that the pre-distribution value of XYZ

(it’s value before distributing cash to shareholders) is $200. Each share is

thus worth $100.

The figure to the left of the ―=‖ shows a stock repurchase in which

XYZ repurchases B’s share for $100. The effect of the repurchase is that (1) B

has sold his share for $100; (2) XYZ has distributed $100 in cash; and (3) A

owns XYZ’s single share (100% of XYZ’s equity), which is worth $100 ($200

pre-distribution value less $100 paid to B).

The figures to the right of the ―=‖ show a two-step transaction: First,

A buys B’s share for $100. Second, XYZ distributes a dividend of $100 to A

(to reimburse A for his purchase of B’s share). The exchange component of

the transaction has no distributional effect because A is buying B’s share for

its proper value -- $100. Thus, both A and B end up with cash or stock worth

$100.



2. Effect when Repurchase Price Exceeds Stock’s Actual Value



Now consider the situation in which the actual value of the stock is

less than the repurchase price. Suppose, for example, that there is bad news

not yet reflected in the stock price.



As Section A explained, a repurchase’s redistributional effect is

equivalent to the that of the remaining shareholders purchasing the shares of

departing shareholders a the repurchase price. When the stock’s actual value

is less than the repurchase price, the repurchase thus transfers value from

remaining to selling shareholders. In effect, the remaining shareholders buy

the shares of departing stockholders at an inflated price.



When the stock’s actual value is below the repurchase price, the

amount of the transfer from remaining shareholders equals the difference

between the repurchase price and the actual value of the stock, multiplied by

the number of shares repurchased. The remaining shareholders bear the cost

of the transfer pro rata. Thus, the higher is a shareholder’s proportional

ownership, the greater the cost borne by that shareholder.

Now suppose that the pre-distribution value of XYZ is not $200 but

rather $150. Each share is thus worth $75.









- 22 -

Corp XYZ = Corp XYZ + Corp XYZ

$150 $50 $150 $150 $50





1 $100 $100

share



A B A $100 B A

1 share 1 share 2 shares

1 share

worth $75

Result



 A gets 100% of Corp.

XYZ (worth $50)

 B gets $100









The figures to the left of the ―=‖ show a stock repurchase in which

XYZ repurchases B’s share for $100. The effect of the repurchase is that (1) B

has sold his share for $100; (2) XYZ has distributed $100 in cash; and (3) A

owns XYZ’s single share (100% of XYZ’s equity), which is worth $50 ($150

pre-distribution value less $100 paid to B).

The figures to the right of the ―=‖ show a two-step transaction: First,

A buys B’s share for $100. Second, XYZ distributes a dividend of $100 to A

(to reimburse A for his purchase of B’s share). The trading component of

the transaction redistributes value between A and B because A is buying B’s

share for $100, even though it is actually worth only $75. A and B each

started with stock worth $75. The $25 transfer from A to B means that B ends

up with $100 and A ends up with $75.





3. Effect When Repurchase Price Below Stock’s Actual Value





Finally, consider the opposite situation – that in which the actual

value of the stock is greater than the repurchase price. Suppose, for example,

that there is undisclosed good news which, when released, will cause the

stock price to increase.







- 23 -

The repurchase’s redistributional effect is, again, equivalent to that of

the remaining shareholders buying the shares of departing shareholders at

the repurchase price. When the stock’s actual value exceeds the repurchase

price, the repurchase therefore transfers value from departing to remaining

shareholders. In effect, the remaining shareholders buy the shares of

departing stockholders at a bargain price.

When the stock’s actual value is above the repurchase price, the

amount of the transfer to remaining shareholders equals the difference

between the actual value of the stock and the repurchase price, multiplied by

the number of shares repurchased. The remaining shareholders enjoy the

transfer pro rata. Thus, the larger is a shareholders’ proportional ownership,

the greater is his share of the transfer.

For example, now suppose that the pre-distribution value of XYZ is

$300. Each share is thus worth $150.









Corp XYZ = Corp XYZ + Corp XYZ

$300 $200 $300 $300 $200





1 share $100 $100



$100



A B A B A

1 share 1 share 1 share 2 shares

worth $50





Result

 A gets 100% of Corp. XYZ

(worth $200)

 B gets $100









The figures to the left of the ―=‖ show a stock repurchase in which

XYZ repurchases B’s share for $100. The effect of the repurchase is that (1) B

has sold his share for $100; (2) XYZ has distributed $100 in cash; and (3) A

owns XYZ’s single share (100% of XYZ’s equity), which is worth $200 ($300

pre-distribution value less $100 paid to B).

The figures to the right of the ―=‖ show a two-step transaction: First,

A buys B’s share for $100. Second, XYZ distributes a dividend of $100 to A





- 24 -

(to reimburse A for his purchase of B’s share). The exchange component of

the transaction redistributes value between A and B because A is buying B’s

share for $100, even though it is actually worth only $150. A and B each

started with stock worth $150. The $50 transfer from B to A means that B

ends up with $100 and A ends up with $200.



IV. THE PROBLEMS WITH COUPLING A REDISTRIBUTION TO A DIVIDEND





In Part III, I explained how the repurchase’s redistributional effect can

transfer value to or from remaining shareholders. This Part examines the

distortions that can arise because of the repurchases’ redistributional effect.

Section A describes the considerable amount of evidence indicating that

managers do use the redistributional effect to transfer value from selling

shareholders to themselves and other remaining shareholders when the

actual value of the stock exceeds the repurchase price. Section B then

describes the distortions that can result from managers’ use of repurchases

for this purpose.







A. Managers’ Use of the Redistributional Effect to Enrich Themselves





This Section explains why managers have the incentive and ability to

use the repurchase redistributional effect for the benefit of themselves and

other remaining shareholders, and presents evidence that they indeed do so.





1. Managers’ Incentive to Transfer Value to Themselves and Remaining

Shareholders





As Part III.C. explained, when the stock’s actual value exceeds the

repurchase price, the repurchase transfers value from departing shareholders

to remaining shareholders. The value transferred is shared ratably among

the remaining shareholders. Thus, to the extent managers retain their shares,

the repurchase benefits them. Everything else equal, managers holding

shares in the firm would therefore have an incentive to conduct such a

repurchase.

The benefit to the managers is increasing in the total amount

transferred and the managers’ proportional interest in the post-repurchase

firm. As a result, the higher managers’ proportional ownership, the greater

the incentive to repurchase shares when the stock’s actual value exceeds the







- 25 -

repurchase price.

In fact, managers of firms announcing repurchases tend to own a

substantial fraction of the firms’ shares before the repurchase: an average of

15-20%.55 In fact, managers capture an average of one out of every five or

six dollars of value transferred from selling shareholders to remaining

shareholders, providing them with significant incentive to conduct

repurchases when the stock is underpriced. Moreover, there is a positive

relationship between pre-repurchase managerial ownership and post-

repurchase stock appreciation,56 suggesting that managers with larger stakes

are more likely than managers with smaller stakes to conduct a repurchase

when the stock is underpriced.



2. Managers’ Ability to Transfer Value to Themselves and Remaining

Shareholders



a. Access to Inside Information



What types of information can managers trade on? There is

considerable evidence that managers have important private information

relating to firm value by virtue of their positions within their firms. The most

persuasive evidence is that managers are able to exploit private information

about firm value to increase their personal trading profits. Managers

increase their selling before releasing ―bad news‖ and increase their buying

before releasing ―good news.‖57 For example, corporate insiders sell heavily

in the five-month period preceding a bankruptcy announcement.58 Corporate

insiders also tend to frequently exercise options shortly before stock price

declines.59 Finally, corporate insiders as a group consistently earn excess

returns in their personal trading.60 One study found that in their personal

trading between 1984 and 1989, which includes, presumably, trades not

based on inside information (e.g., liquidity-driven sales), managers annually







55 See McNally, supra note , at 59; Vafeas, supra note , at 112-13.

56 See Raad and Wu, Insider Trading components on Stock Returns Around Open-

Market Repurchase Announcement: An Empirical Study, 18 J. FIN. RES. 45, 57 (1995) (finding

that abnormal returns following repurchases are positively related to pre-buyback

insider buying and the level of pre-buyback management ownership).

57 See Fried, supra note x, at 317-20 (collecting and summarizing studies).

58 See Thomas Gosnell et al., Bankruptcy and Insider Trading: Differences Between

Exchange-Listed and OTC Firms, 47 J. Fin. 349, 350-53 (1995); H. Nejat Seyhun & Michael

Bradley, Corporate Bankruptcy and Insider Trading, 70 J. Bus. 189 (1997).

59 See Steven Huddart & Mark Lang, Information Distribution Within Firms: Evidence

from Stock Option Exercises (working paper, 2001).

60 See Fried, supra note x, at 321-23 (collecting and summarizing studies).





- 26 -

earned excess returns averaging 7%. 61

To the extent managers can use inside information to increase their

personal trading profits, they can also use this information to benefit

themselves and other remaining shareholders by having the firm repurchase

stock at a bargain price. Indeed, there are a number of factors that make it

easier for managers to buy indirectly through repurchases than to buy

directly for their own accounts when the stock is underpriced.

First, liquidity constraints might make it difficult for managers to buy

shares for their own accounts, or buy as many shares as they would like.

Such liquidity-constrained managers might purchase shares in the market to

the extent permitted by their liquidity constraints and, after they have

reached those constraints, conduct a repurchase. In fact, managers

frequently do buy shares for their own accounts before announcing

repurchases.62

Second, section 16(b) of the Securities Exchange Act of 1934, which

prohibits managers (but not the firm) from making ―short swing profits,‖

might prevent managers from buying shares.63 A corporate insider is

considered to make a short-swing profit if he or she buys stock and sells

stock within a six-month period, the purchase price is lower than the sale

price. The rule applies not only when the purchase precedes the sale, but

also when the sale precedes the purchase. A manager who either has sold

shares at a higher price within the previous six months or expects to sell

shares at a higher price within the next six months will expect to face section

16(b) liability if he buys stock on the market. However, indirect purchases of

stock through a share repurchase are not subject to section 16(b). Thus, such

a manager will not face section 16(b) liability if he indirectly buys stock

through a repurchase.

Third, many firms restrict the trading of managers and directors

through the use of ―trading-windows‖ and ―blackout‖ periods, which permit

corporate insiders to trade only during certain prescribed periods

throughout the year.64 Thus some managers may be subject to firm-imposed

trading restrictions at a time when they believe the stock to be underpriced

and wish to purchase shares. Because of these three types of restrictions,

managers may often prefer (or be forced) to buy shares indirectly through a



61 See H. Nejat Seyhun, The Effectiveness of Insider Trading Sanctions, 35 J.L. & Econ.

147, 158-60 (1992).

62 See Elias Raad & H.K. Wu, Insider Trading Effects on Stock Returns Around

Open-Market Stock Repurchase Announcements: An Empirical Study, 18 J. FIN. RES.

45, 57 (1995).



63 15 U.S.C. § 78p(b) (2001).

64 See J. Carr Bettis et al., Corporate Policies Restricting Trading by Insiders, 57 J.

Fin. Econ. 191 (2000).





- 27 -

repurchase in addition to, or instead of, buying shares for their own

accounts.



b. The Law’s Inability to Prevent Managers’ Use of Inside

Information



There are, of course, legal restrictions that apply to managers and

firms trading on ―inside information.‖65 One might wonder, then, how

managers are able to use their private information to either buy shares for

their personal accounts or have their firms buy shares at a low price.

The most important legal restriction on insider trading is Rule 10b-5,

which was promulgated by the SEC under section 10 of the Securities

Exchange Act of 1934.66 Rule 10b-5 requires that any insider (including the

corporation itself) with a fiduciary duty to those with whom the insider

would trade refrain from trading if in possession of ―material‖ inside

information.67 Rule 10b-5 thus appears on its face to prevent the managers

from repurchasing shares when they know the stock is underpriced.

However, as I have shown elsewhere,68 there are likely to be many

cases in which Rule 10b-5 cannot prevent insiders – including the

corporation – from trading profitably on inside information. Rule 10b-5

prohibits trading on inside information only when that information is legally

―material.‖69 And much inside information is not legally material. First,

internal projections and other forms of ―soft‖ information are not considered

legally material, even if the information is important and would be of great

interest to investors.70 Thus, managers are free to trade and to conduct share

repurchases without disclosing a wide range of valuable but inside





65 By Ainside information,@ I mean nonpublic information relating to the value of

the firm=s shares that is available to managers by virtue of their positions within the

corporation, whether or not that information would be considered legally Amaterial.@

66 17 C.F.R. § 240.10b5 (2000).

67 See Fried, supra note x, at 330.

68 See Fried, supra note x.

69 See United States v. O’Hagan, 521 U.S. 642, 643 (1997).

70 For example, in Walker v. Action Indus., 802 F.2d 703 (4th Cir. 1986), managers

conducted a repurchase tender offer (RTO) for $4.00 per share and three months later

the market price rose to $15.75. The court found that there was no violation of the

securities laws even though at the time of the RTO there were undisclosed forecasts

predicting a substantial increase in orders and sales. See also John Coates, A Fair Value as

an Avoidable Rule of Corporate Law: Minority Discounts in Conflict Transactions, 147 U.PA.

L. REV. 1251, 1315 (1999) [RA: add parenthetical]; Mitu Gulati, When Corporate Managers

Fear a Good Thing is Coming to an End: The Case of Interim Nondisclosure, 46 UCLA L. REV.

675, 682 (1999) (reporting that recent case law and the SEC’s position is that companies

are not obligated to disclose forecasts).





- 28 -

information.71 Second, courts have been reluctant to find even non-soft

information ―material‖ unless it concerns a ―bombshell event‖—such as the

definite existence of a takeover offer—whose announcement dramatically

changes the stock price.72 Thus, the threshold of materiality is such that

insiders can easily profit by trading directly or indirectly through

repurchases on information that, while price-sensitive, is not legally

material.73



c. Why the Required Repurchase Announcement Doesn’t Fully Reveal

the Underpricing



If the firm has not already announced the initiation of an open market

repurchase program, then before repurchasing any shares the firm must,

under stock exchange rules, announce the initiation of the program. The

announcement will, in turn, boost the stock price, narrowing the gap

between the share price and the stock’s actual value, and making it more

difficult for the managers to profit by buying the shares of selling

shareholders.74

However, it is unlikely to close the gap because the ―signal‖ sent by

the announcement is ambiguous. The firm might simply be giving itself the

option to repurchase shares should they become underpriced in the future.75

For example, Continental Airlines recently announced a program that is of

indefinite duration, perhaps obviating the need to ever announce such a

program again.76 Or, as I will explain shortly, the managers might be

announcing the program simply to boost the stock price before selling their

own shares.77 Knowing that these are possible reasons for the announcement,



71 See Fried, supra note, at 310; Robert Clark, supra note, at 507-08 (noting that

managers may have access to bits of information that individually are not important

enough to be considered legally material but which in aggregate are very valuable);

Donald Langevoort, Rereading Cady, Roberts: The Ideology and Practice of Insider Trading

Regulation, 99 COLUM. L. REV. 1319, 1335 (1999) (observing that [i]nsiders at almost all

times have the advantage of superior insight and a sense of which way things are going

even if they do not possess a fact that a court would call material and nonpublic).

72 See Fried at 336.

73 See Dennis W. Carlton & Daniel Fischel, The Regulation of Insider Trading, 35 Stan.

L. Rev. 857, 886-87 (1983). There are also situations in which the probability of detection

and punishment for illegal insider trading is so low that managers may well not be

deterred from engaging in it. See Fried, supra note x at 331-335.

74 In Part VI, I consider the possibility that stock repurchases might boost the stock

price by taking stock out of the hands of the lowest-valuing shareholders. To the extent

repurchases exert such price pressure, the gap will be narrowed further.

75 See Ikenberry and Vermaelen, supra note x.

76 See Grullon and Ikenberry, supra note x.

77 See infra Part IV.C.





- 29 -

the market’s reaction will be muted -- even if the market is perfectly efficient.

In fact, the shares of firms announcing repurchases exhibit large

abnormal returns in the months and years following the announcement.

This indicates that the market on average underreacts to the information

signaled by the repurchase announcement (that is, the stock price does not

adjust to reflect all of the information available about its value). Because the

market underreacts to the repurchase announcement, it is even easier for

managers to benefit themselves and remaining shareholders by buying

shares through the firm when the stock is underpriced.78



d. Cash and Flexibility Constraints on Repurchases



That is not to say that managers have an almost unlimited ability to

use the redistributional effect of repurchases to transfer value to remaining

shareholders. To begin, the firm might face cash constraints. That is, it

might not have enough cash on hand to fully exploit a temporary gap

between the actual value of the stock and the share price. Alternatively, the

firm might have the cash, but prefer to use it for other (real) investments that

are likely to earn remaining shareholders an even higher return. These cash

constraints will limit managers’ ability to exploit mispricing.79

In addition, even if the firm is not cash-constrained, the firm might

be reluctant to buy a large number of shares in a short period of time. There

could be two reasons for such reluctance. First, managers might fear that

large purchases will signal that the stock is underpriced, forcing the price of

the stock up and significantly reducing the amount of value transferred to

remaining shareholders.80

Second, managers might wish to comply – or substantially comply –

with Rule 10b-18, which provides a safe harbor from manipulation liability

for firms which limit the daily volume of their repurchases and adhere to

other restrictions. Either of these concerns will limit managers’ ability to

exploit mispricing even if they are not cash constrained.



3. Evidence Managers Use Repurchases to Transfer Value



Having seen that managers have the incentive and ability to use a

repurchase’s redistributional effect to benefit remaining shareholders, we



78 See infra Part IV.B.3.

79 The firm might be able to raise funds by issuing debt, but there is likely to be a

time lag during which the stock might become fairly priced (or even overpriced). In

addition, the costs of issuing additional debt (e.g., excessive leverage) might exceed the

expected benefit from buying the stock at a low price.

80 The firm might also fear that the purchases will exert price pressure. See infra

Part VI.





- 30 -

now turn to the considerable evidence that is consistent with managers using

repurchases to transfer value from selling shareholders to remaining

shareholders. The evidence can be divided into two categories: (1) price

movements before, around the time of, and in the years following the

repurchase announcement; and (2) managers’ behavior before, during, and

after the repurchase announcement.

Consider first the stock prices of firms announcing repurchases. The

stock prices of firms announcing repurchases on average exhibit negative

abnormal returns in the period prior to the announcements 81, which is

consistent with the shares having been underpriced at the time of the

repurchase.82 When the repurchase is announced, the market reacts to the

announcement by bidding up the price of the stock. This reaction is

consistent with the announcement sending a signal that the stock is

underpriced.83 Finally, and most importantly there are abnormal price

increases averaging 12% over the forty-eight months following repurchase

announcements.84 These post-repurchase returns provide extremely strong

evidence that as a group, firms announcing OMRs are underpriced at the

time the repurchase is announced.85





81 Jagannathan and Stephens, supra note x report that for infrequent or occasional

repurchasers (firms which conducted only 1 or 2 repurchases respectively in the

previous 5 year period) average returns in the year before the announcement are 11%

and 5%, respectively, below those of peer firms.

82 Firms announcing first time repurchases have high book to market ratios, which

is consistent with their being underpriced. See Grullon and Ikenberry, supra note x.

Of course, the negative abnormal returns prior to the repurchase announcement

do not prove that the stock was underpriced at the time of the announcement. It is

possible that the stocks were overpriced prior to the negative abnormal returns and

that those negative abnormal returns simply corrected the overpricing.

83 Of course, the positive reaction to the repurchase announcement does not prove

that the market infers from the announcement that the stock is underpriced. There are a

number of reasons why the stock price might increase in response to such an

announcement. For example, the announcement might signal that managers are finally

willing to distribute cash for which they have no good investment opportunities. Part

VII.A. provides a number of other non-informational explanations why a repurchase

announcement might boost the stock price.

84 See Ikenberry, Lakonishok, and Vermaelen, supra note, at 190 (reporting large

price increases following OMRs undertaken between 1980 and 1990). See also Chan,

Ikenberry and Lee, Do Managers Knowingly Repurchase Stock on the Open Market

(examining long-horizon returns for a sample of over 4000 open market programs

announced by US firms from 1980 to 1996 and finding [RA: complete]) (working paper,

2000).

85 The subsequent abnormal price increases do not prove that the stock is

underpriced at the time of the repurchase announcement because there could be

another explanation for the post-announcement price increases: that firms conducting





- 31 -

Next consider managerial behavior. First, there is some evidence that

managers buy more shares for their personal accounts before repurchases

that are followed by significant stock price appreciation, 86 suggesting that

they are aware that the stock is underpriced prior to the announcement.

Second, firms are more likely to follow up a repurchase announcement with

actual repurchases if the stock performs poorly.87



4. A Note on Managers’ Use of Repurchase Announcement to Boost the Stock

Price Before Selling



We have seen that managers can -- and do -- use the redistributional

effect of repurchases to transfer value to remaining shareholders when the

actual value of the stock exceeds the stock price. Market participants are not

unaware of this fact. Thus, market participants are likely to infer from a

repurchase announcement that the stock may be underpriced, and bid up the

price of the stock upon hearing the announcement. 88

Of course, not all repurchases are motivated by managers’ desire to

transfer value to remaining shareholders. There are likely to be repurchases

that have other motivations. For example, managers may repurchase shares

in order to distribute excess cash in a tax efficient manner, or as we will see

in more detail, to ―fund‖ option programs. Thus investors cannot be certain

that a particular repurchase is motivated by managers’ desire to purchase

stock for themselves and remaining shareholders at a low price.89



repurchases boost the price of their shares by buying back shares from their lowest-

valuing shareholders. This possibility is discussed infra Part VI.

If price pressure does not explain at least part of the subsequent abnormal stock

price increases, then the underreaction to repurchase announcements is quite puzzling,

as it seems to provide investors with significant arbitrage opportunities which, when

exploited, would tend to increase the reaction to the repurchase announcements and

reduce the subsequent abnormal price increases (in other words, arbitrage should

accelerate those price increases so that they occur when the repurchase is announced,

rather than after).

86 See Raad and Wu, Insider Trading components on Stock Returns Around Open-

Market Repurchase Announcement: An Empirical Study, 18 J. FIN. RES. 45, 57 (1995)

(showing that abnormal returns following OMRs are positively related to pre-buyback

insider buying and the level of pre-buyback management ownership). But see Chan,

Ikenberry, Lee (finding no evidence that managers buy around repurchases that

precede large price increases)(working paper, 2000).

87 See Stephens and Weisbach, supra note x.

88 There are other reasons that market participants might react favorably to a

repurchase announcement besides the signal it sends about the actual value of the stock.

For example, investors might bid the price up because they believe the firm will

distribute excess cash that it had been holding and that was earning poor returns.

89 Interestingly, there is evidence that the reaction is lower when the market

believes that the repurchase is intended to fund option plans. In particular, the reaction





- 32 -

However, even if many repurchases are motivated by other reasons a

repurchase announcement signals that the expected value of the stock is likely

to be higher than the pre-announcement market price. This, in turn, suggests

that managers intending to sell shares might announce a repurchase in order

to boost the price of the stock before selling the shares, even if they have no

immediate intention of repurchasing any shares.

To be sure, average stock price reactions to repurchase

announcements is fairly modest, 3-4%. 90 However, there are abnormal

returns averging 7-8% when smaller firms announce repurchases and when

the announcement has not been preceded by another in the last five years. In

any event, for managers selling millions of dollars worth of shares, as well as

managers exercising options whose strike price is close to the pre-

announcement market price, the ability to sell shares at even a slightly higher

price may well be significant. Essentially, managers who wish to sell shares

attempt, by announcing a repurchase, to "mimic" or "pool" with managers of

underpriced firms who are using a repurchase to buy stock at a low price.

To the extent that the market cannot distinguish between the different types

of firms, the repurchase announcement boosts the stock price, enabling the

mimicking managers of to sell their shares at a higher price.91 The presence

of overpriced firms in the pool of firms announcing repurchases dampens

the price reaction to repurchase announcements. This price-dampening

inures to the benefit of managers of underpriced firms, by enabling them to

buy shares for themselves and other remaining shareholders at a lower price.

Thus, mimicking by selling managers of indirectly buying benefits all

managers announcing repurchases.

There is evidence consistent with the use of repurchase

announcements to boost the stock price before managers sell shares: at least

one study reports that mean and median insider percentage ownership fall

around the time of repurchase announcements.92 In addition, Jagannathan





is lower when there are a large number of employee options outstanding. See

______Kahle, supra note x, at 6. See infra Part __ for a discussion of the need for

repurchases to fund option plans. See also Jagannathan and Stephens, Motives for

Multiple Open-Market Repurchase Programs (working paper, 2001)(reporting that the stock

market reaction to first time repurchases is higher than that to multiple repurchases by

the same firm in a 5 year period, presumably because the firm conducting multiple

repurchases has different motives for repurchasing – such as distribution of excess cash

and acquisition of shares to fund option programs).

90 See supra note.

91 Cf. Bhattacharya & Dittmar, supra note, at 27 (reporting that there is no

difference in market reaction between OMR announcements followed by repurchases

and OMR announcements not followed by repurchases).

92 See Vafeas, supra note. In addition, Chan, Ikenberry, and Lee find that

repurchase announcements occur around time executive options are exercised.





- 33 -

and Stephens find that although the average post-repurchase returns of

infrequent and occasional repurchasers are positive, the median is

significantly negative relative to the market, which is consistent with many

firms having been overpriced.93 Because it is unlikely that in all of these

overpriced firms managers were planning to repurchase shares, and given

managers’ tendency to sell when they know the stock is overpriced, it is

likely that at least some of these repurchase announcements were made by

managers solely with the intent of boosting the stock price before selling

their shares.



B. Potential Distortions



This Section describes the potential distortions that can result from

managers’ use of repurchases to transfer value from public shareholders.

Section A describes what I call the ―under-investment distortion;‖ when the

stock is sufficiently underpriced, managers may have an incentive to conduct

a repurchase even when from an efficiency perspective the cash is better

invested in the firm. Section B describes the second distortion likely to arise

from the use of repurchases to transfer value: that managers are likely to

maintain excessively large cash reserves (―the cash-hoarding distortion‖).

Third, as Section C explains, repurchases can give rise to an ―under-

disclosure distortion‖ - managers may have an incentive to delay the

disclosure of important information.



1. Underinvestment



We saw that the dividend component of a repurchase could either be

efficient or inefficient – depending on the direction and magnitudes of its

two effects: (1) the cash-distribution effect; and (2) leverage-altering effect.

The first problem with coupling a redistributional transaction to a dividend

is that it might encourage managers to conduct repurchases whose dividend

component is not value-decreasing.



Consider the case in which the managers have private information

about the value of the stock and know that the stock is underpriced. In that

case, the managers know that, if they repurchase shares, the redistributional

component of the repurchase is going to make remaining shareholders –

including the managers – better off. In essence, a repurchase would cause

the remaining shareholders to buy the shares of selling shareholders at a low

price. To the extent that the managers continue to hold shares – they will



93 See Jagannathan and Stephens, Motives for Multiple Open-Market Repurchase

Programs (working paper, 2001).







- 34 -

have an incentive to repurchase shares, everything else equal.

Of course, everything is not equal. The managers will also consider

the value that can be created by the dividend component of the repurchase.

In particular, they will consider the possibility that a repurchase can be used

to distribute excess cash or improve leverage. If the dividend component

would create value, then the managers would have a stronger incentive to

conduct a repurchase because it boosts the value of remaining shares in two

ways – by creating value and transferring value from selling shareholders.

However, if the dividend component reduces value – the managers

may still have an incentive to repurchase shares. Specifically, they will

repurchase shares if the value transferred to selling shareholders exceeds the

value created by the repurchase for remaining shareholders.

Suppose that A and B each own 50% of XYZ Corporation. The market

values XYZ at $200, or $100 per share. However, the manager (A) knows that

XYZ is actually worth $300. In the absence of a repurchase, A’s 50% interest

is worth $150 (1/2 x $300). But A contemplates having XYZ Corporation

repurchase B’s share for $100, $50 less than it is actually worth. In the

absence of an efficiency effects, such a repurchase would transfer $50 to A

(by leaving him with 100% of a firm worth $200).

However, suppose there would be some efficiency costs to such a

repurchase. Specifically, suppose that such a repurchase would reduce XYZ’s

value by an extra $25 (beyond the $100 paid out to B) because XYZ would

need to forego certain high value projects in order to ―finance‖ the

repurchase. Nevertheless, A decides to go forward with the repurchase,

because at the end of the repurchase he will own 100% of a firm worth $175,

while in the absence of a repurchase his interest would be worth only $150.









Corp XYZ = Corp XYZ + Corp XYZ

$300 $175 $300 $300 $175





1 share $100

$100

$100

A B A B A

1 share 1 share 2 shares

1 share worth $150









- 35 -

There is some evidence consistent with repurchases reducing firm

value. A recent study comparing repurchasing firms in the U.S. to

nonrepurchasing firms found that the nonrepurchasing firms’ stock

outperformed that of repurchasing firms. The authors reported that the

higher investments by nonrepurchasing firms in working capital and capital

projects were largely responsible for the performance gap.94

To be sure, a firm might be able to borrow money to fund the

repurchase, which would reduce the problem of distributing cash better

invested in the corporation. But borrowing might be difficult, either because

bond covenants prohibit or because it takes too much time, during which the

underpricing might disappear. And even if borrowing were possible,

managers might not want to increase the firm’s interest burden and the

likelihood of financial distress.





2. The Cash-Hoarding Distortion



Another distortion that can arise from the use of repurchases is

excessive liquidity – maintaining cash reserves that are too large. The

reserves are too large in the sense that they money would be better invested

outside of the firm. However, from the perspective of remaining

shareholders, it might make sense to keep the cash in the firm because

managers know, or think likely, that the stock price will fall below its actual

value (by over-reacting to bad news) or that there will be good news that will

not be reflected in the stock price), and having cash available in the firm is

necessary to take advantage of that discrepancy.



As will be explained, the problem of cash-hoarding also arises when

the stock is overpriced and for that reason managers do not repurchases

shares. That is, managers might have an incentive not to conduct a (value-

increasing) repurchase even though the dividend-component is value-

increasing because they have private information indicating that the stock is







94 See John Evans and James Gentry, ―Do Strategic Share Repurchase Programs

Create Long-Run Firm Value‖ p. 24 (working paper, 2000). See also Robert O’Brien,

―Stock Buybacks Gain Popularity, But Price Pops Aren’t Guaranteed‖, Wall St. Journal

p. 17 Column 3 (3/6/00) (citing research report by chief investment strategist of Credit

Suisse First Boston as saying that ―heavy repurchases are counterintuitively associated

with poor share performance‖). Of course, it is not clear in which direction causality

runs. It is possible that poorly performing companies without attractive investment

possibilities are more likely to distribute (excess) cash than companies with better

opportunities.





- 36 -

overpriced and thus decide to postpone the repurchase until the stock is

correctly priced or underpriced.





a. Waiting for the Next Insider Trading Opportunity



Suppose that ABC Co, with 10 shares outstanding has $V in operating

assets and $10 in cash. Suppose that $V = $180 or $0 with equal likelihood.

Managers will learn the value at the beginning of next period, before the

public. Right now the stock has an expected value of $10 and (let us assume)

is trading for $10.95 The $10 in cash sitting in the firm will generate $0

during the current period. If it is distributed, the $10 in cash will generate $1

of profit. (Assume that if the $10 is invested in the firm’s operations it also

generates no return).

From an efficiency point of view, the $10 should be distributed. But

the managers and other remaining shareholders are better off if the $10 is not

distributed, but rather kept in the firm so that if $V = 180, and the shares are

actually worth $19 per share, they can buy a share for $10 and boost the

value of their shares to $20.



b. Waiting for an Overpriced Stock to Fall



Now consider the case in which the managers have private

information about the value of the stock and know that the stock is

overpriced. And suppose the only method available for ABC’s managers to

distribute cash is a share repurchase. (I will justify this assumption shortly).

In that case, the managers know that if they repurchase shares the

redistributional component of the repurchase is going to make remaining

shareholders – including the managers – worse off. In essence, a repurchase

would cause the remaining shareholders to buy the shares of selling

shareholders at an inflated price. To the extent that the managers’ interests

are aligned with those of remaining shareholders – because they continue to

hold shares – they will have an incentive not to repurchase shares,

everything else equal.

Of course, everything is not equal. The managers will also consider

the value that can be created by the dividend component of the repurchase.

Again, they will consider the possibility that a repurchase can be used to

distribute excess cash or improve leverage. If the dividend component is





95 Because of the possibility that the managers will decide to purchase the stock

when it is underpiced, the price will be slightly discounted from $10. But I ignore this

complication because it does not affect the analysis.







- 37 -

value-reducing, then the managers will certainly not conduct a repurchase.

Under this scenario, there would be no problem of excessive payouts.

However, now – if the dividend component creates value – they will

have an incentive to repurchase shares only if the value created by the

repurchase for remaining shareholders exceeds the value transferred to

selling shareholders. If the dividend component would create value but less

than the value transferred to selling shareholders, the managers will not

have an incentive to conduct a repurchase. Instead, they will wait until the

stock price falls sufficiently to make the repurchase worthwhile and then

distribute the cash. During this interim period, when the repurchase is

delayed, there is an efficiency cost.

We were assuming in this subsection that the only way to distribute

cash is through a repurchase. If we relax that assumption, when the stock is

overpriced, the firm could simply issue a dividend which has no

redistributional component. This would solve the problem of the delayed

cash distribution.96 However, such a dividend would signal that the stock is

overpriced and cause the price to fall, making it difficult for managers to sell

their own shares at as high a price. Thus managers might not issue a

dividend even if it would be efficient to do so.





C. Reduced Disclosure



In Part III.B we saw that share repurchases can, through the dividend

component, affect managerial effort and project-choice ex post -- that is, after

the transaction. Share repurchases -- and in particular the use of repurchases

for insider trading - can also affect managerial incentives ex ante. In

particular, when managers know that they may later have an opportunity to

use a share repurchase to indirectly buy the stock at a low price or sell it at a

high price, their managerial incentives could become distorted.



In particular, the use of share repurchases to buy low and sell high

encourages managers to invest in projects that are difficult for outsiders to

assess, whether these projects are otherwise desirable or not, in order to

increase the information asymmetry between themselves and public

shareholders so they can make more money buying low or selling high.97 In

addition, the use of share repurchases for insider trading can cause managers

to distort or withhold information, or to mislead the public, especially



96 See Bhagwan Chowdhry and Vikram Nanda, Repurchase Premia as a Reason for

Dividends: A Dynamic Model of Corporate Payout Policies, 7 REV FIN STUD 321

(1994)(arguing that dividends allow corporations to distribute cash more cheaply when

the stock is overvalued).

97 See Fried, supra note x, at ___.





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around the time of the share repurchase, in order to maximize the

information asymmetry between the managers and public shareholders.98





V. ARGUMENTS FOR REPURCHASES



In Part III we saw that a repurchase can be decomposed into a

dividend and a redistributional component and therefore that a repurchase

can give rise to all of the potential efficiency benefits and costs of a dividend.

Part III.B elaborated on those costs and benefits associated with the dividend

component and showed that the dividend component of a repurchase could

be either value-creating or value-destroying. Part IV showed that the

redistributional component of the repurchase could distort the payout and

investment policies of the firm by encouraging managers to repurchase

shares when a payout is value-reducing and maintain excessive liquidity

when a payout of the funds in the firm would be value-increasing. In

addition, the use of repurchases could reduce disclosure.

This Part considers the possibility that there might be countervailing

benefits unique to repurchases whose existence should be considered in

determining the desirability of share repurchases relative to dividends. The

finance literature suggests four types of efficiency benefits associated with

repurchases but not dividends.

First, repurchases might provide firms with more financial flexibility

than dividends (Section A). Second, repurchases are said to allow firms to

credibly signal information about the value of the shares (Section B). Third,

repurchases might impose fewer transaction costs on shareholders than do

dividends (Section C). Fourth, repurchases are said to be necessary for

providing shares for stock option incentive plans (Section D).

Each of these benefits will be examined in turn. As will be explained,

each of these benefits is achievable solely with dividends or more efficiently

accomplished with dividends and some other mechanism. It is important to

emphasize here that I am not suggesting that repurchases be prohibited. I am

claiming, however, that if repurchases were prohibited all of the efficiency

benefits could easily be achieved through other mechanisms.









98 In this way, using the share repurchases for insider trading may have the same

adverse effects on price efficiency as Apersonal@ insider trading, which gives managers

an incentive to delay disclosing information to the market or to deliberately provide the

market with misleading information. See Fried, supra note x, at n.54 and surrounding

text.





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A. Financial Flexibility



The first benefit attributed to repurchases is financial flexibility. It

has been argued that share repurchases give firms more financial flexibility

than dividends because paying a dividend implies to the market a

commitment to make future distributions.99 Thus when there is a one-time

need to distribute cash, firms cannot issue dividends because that would

falsely raise investors= expectations about the future cash flow of the firm. In

fact, there is evidence that firms with transient positive cash flow shocks use

repurchases rather than dividends to distribute the cash.100

The main problem with this explanation is that for decades firms have

used so-called Aspecial@ (one-time) dividends to distribute cash in situations

where the cash flow used to finance the dividend was not likely to be

recurring. Because a special dividend could be used in place of a repurchase,

repurchases are not necessary to give a firm financial flexibility.



B. Share-Value Signaling



A second possible benefit of repurchases is share-value signaling.

Specifically, managers who have private information indicating that the

stock is underpriced and wish to signal credibly that the stock is underpriced

can use the redistributional component of a share repurchase to do so by

conducting a repurchase and committing not to sell their shares. 101

As this Section will explain, however, share-value signaling is

inconsistent with managers’ interests and managers never use repurchases to

signal in this manner. Furthermore, if managers wished to engage in such

signaling, they need not conduct a repurchase to do so.



1. The Potential Benefit



To the extent that managers seek to maximize shareholder wealth,

they will wish to communicate good news to the market to boost the stock

price. However, direct disclosure of the good news is not always possible. 102



99 There is a considerable literature explaining how firms that initiate or increase

dividends send a signal to the market that long-term cash flows have increased. See, e.g.,

John and Williams (1985); Bernheim (1991); DeAngelo, DeAngelo, and Skinner (2000).

100 See Guay and Harford, supra note x. See DeAngelo, DeAngelo, and Skinner,

supra note x; Jagannathan, Stephens, and Weisbach, supra note x (finding that firms that

pay dividends have more stable earnings than firms that use repurchases and that

concluding that firms use repurchases to pay out transitory earnings while dividends

are used to payout permanent earnings).

101 See, e.g., Buckley, supra note, at 539.

102 For example, explicit disclosure might be harmful to the firm for competitive





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When direct disclosure is not possible, the managers could instead

simply announce that the stock is underpriced. However, some

commentators believe that signaling is not credible unless it imposes

substantial costs on managers when the stock is not actually underpriced.103

According to these commentators, there is no cost to a manager who falsely

announces that the stock is underpriced.104 An announcement that the stock

is underpriced would therefore not be credible, and would be ignored or at

least highly discounted.105

To credibly signal underpricing, these commentators believe that

managers must act in a way that imposes substantial costs on them if the

stock is not actually underpriced. And these costs must be high enough that

a would-be false signaler would find the signal too costly to send.106

In theory, repurchases can be used to credibly signal that the stock is

worth more than the repurchase price. As we saw any share repurchase

distributionally equivalent to a transaction in which remaining shareholders

collectively buy shares directly from the selling shareholders at the

repurchase price. Thus managers who make a double commitment -- to (1)

have the firm repurchase shares and (2) not sell their own shares until the

underlying good news emerges --- effectively commit to buy their pro rata

share of the repurchased shares at the repurchase price. If firm value is in

fact less than the repurchase price, the repurchase makes managers worse off

by causing them to overpay for the shares.107 Thus by committing to

repurchase shares and to not sell their own shares, managers send a credible

signal that firm value exceeds the repurchase price. 108

Note that for the share repurchase to be a credible signal that the stock

is underpriced, managers must pledge that they will not sell any shares until

the good news signaled by the repurchase is supposed to materialize.109

Otherwise, managers would have an incentive to conduct a share repurchase

when the stock=s actual value is below the repurchase price, indicate that

they will not sell during the repurchase and thereby, falsely signal good





reasons or prohibited by a confidentiality agreement. See Buckley, supra note 16, at 536-

37.

103 See id.

104 See, e.g., id. at 527.

105 Lawless et al, supra note x have also pointed out that fear of legal liability might

prevent managers from disclosing information or beliefs directly to shareholders. See

Lawless, supra.

106 See Buckley, supra note, at 527. See also Spence.

107 By distributing cash, the repurchase also increases risk to the firm, imposing an



additional risk-bearing cost on managers. See McNally, supra note, at 56.

108 See William J. McNally, Open Market Stock Repurchase Signaling, [finish

citation].

109 See Fried (2001).





- 41 -

news, and then sell their shares at a high price after the signal has caused the

market price to rise.



2. The Irrelevance of Share-Value Signaling Through Repurchases





a. Managers Lack an Incentive to Signal Share Value





Consider managers= incentives to signal. Implicit in the signaling

theory is that managers have an incentive to use repurchases to signal

underpricing. But signaling usually requires managers to act contrary to

their self-interest. To begin with, the commitment to retain shares required

by signaling imposes a liquidity constraint on managers. Managers’ stock in

their own firms may well constitute a large fraction of the managers’ assets.

From time to time, managers might have liquidity needs that can be met only

by selling large amounts of these shares. Thus, the commitment to retain

shares that is required by the theory for credible signaling110 could impose a

liquidity cost.

In addition, signaling hurts managers by reducing their ability to

profit from their private information when they know that the stock is

underpriced. By not signaling, managers can keep the stock price

temporarily low. The low stock price enables managers to profit by buying

shares for themselves, either directly or indirectly through a repurchase, at a

price below their actual value. If the managers were to use a repurchase to

signal that the stock is underpriced, the market would bid up the stock price.

This, in turn, would make it more difficult for managers to buy shares for

themselves at a low price. 111

We have just seen that a repurchase signaling hurts managers by

constraining their financial flexibility and reducing their ability to buy shares

at a low price. Let us now consider the possibility that repurchase-signaling

can benefit managers by boosting the stock price, thereby enabling managers

to sell their shares at a higher price than would otherwise be possible. As the

analysis below will make clear, signaling cannot benefit managers in this

manner. The reason is that the managers must be net buyers for the (or at

least not net sellers) for the signal to be credible.



110 As will be explained shortly, managers can credibly signal without pledging to

retain all of their shares. However, for a typical one they must pledge to retain 90-95%of

their shares.

111 To be sure, managers signaling underpricing with a repurchase could still profit

to the extent the market fails to bid the stock price up to its actual value. However, the

managers would be better off not signaling underpricing and buying the shares at an

even lower price. See Fried, supra note x.





- 42 -

Thus, for the repurchase announcement to credibly signal the

existence of good news, the managers must pledge to retain almost all of

their shares until the good news itself emerges. Because managers must

retain almost all of their shares until the good news is revealed, they cannot

use repurchase-signaling to sell their shares at a higher price beforehand.

Whether or not they engage in repurchase-signaling, managers must wait

until the good news itself emerges before they can sell their shares at a

higher price.

But if managers must be net buyers at the repurchase price for the

signal to be credible, they are better off not credibly signaling that the stock is

underpriced, selling shares in the market at a lower price, and indirectly

buying a greater number of shares through an OMR. That is, the managers

are better off being net buyers at a lower price than at the higher, signaling-

induced price.112

To be sure, one can imagine situations in which managers can gain by

increasing the stock price through signaling. To the extent that the signal

boosts the stock price, it makes a takeover more difficult, makes it easier to

use stock to acquire another firm, and enables managers to borrow more

against their shares if the price is higher.

But given that managers always accrue some benefit from not

signaling – for example, they don’t impose restrictions on their trading --

they have an incentive not to signal until and unless there is a specific reason

to do so – such as a hostile takeover attempt. At that point, they can release

the information directly (even though it is not optimal for the firm and its

shareholders) or conduct a repurchase and use it to signal their own beliefs.

In other words, a strategy of not signaling can always be changed if a specific

threat of a hostile takeover or the opportunity of an acquisition arises.

Of course, this discussion is purely hypothetical because, as we will

shortly see, insiders never use open market repurchases to repurchase in the

manner suggested by the share-value signaling theory.



b. Managers Don’t Use Repurchases for Share-Value Signaling



Let us now examine whether in fact managers use the trading

component of repurchases for the purpose of signaling. The data easily

answer this question: they do not.

As explained above, for managers to use the trading component of

share repurchases to signal that the stock is underpriced managers must (1)



112 See Fried, supra note x and numerical examples therein.









- 43 -

indicate the price the corporation is paying for its shares; (2) indicate that a

substantial number of shares will be repurchased, and (3) commit not to sell

their shares for the Aacceleration period@ (the time it would take for the

hidden Agood news@ to emerge on its own).

In fact, managers do not indicate the price that the firm will be paying

for its shares or commit to purchasing a certain number of shares in the

repurchases or even commit to holding on to their own shares.

To begin with, signaling requires firms announcing repurchases to

commit to repurchase a certain number of shares. However, when making

repurchase announcements, managers never commit to purchase a minimum

number of shares.113 Although a repurchase announcement might specify a

target number of shares, the announcing firm makes clear that the actual

number of shares repurchased will depend on market conditions and on

managers’ discretion.114 Approximately 20-30% don’t even indicate the

target amount.115

In fact many firms announcing repurchases subsequently issue shares,

usually to employees and managers exercising stock options. Thus even

those that repurchase X% do not increase managers’ proportional ownership

X%, but rather by X-y%, where y is the stock issued after the repurchase

announcement. In some cases the amount of shares issued could exceed the

shares repurchased. Under circumstances like this, managers proportional

ownership could actually go down in the period following the repurchase

announcement.

One might believe that managers who announce a repurchase and do

not repurchase any shares suffer some form of reputational cost (unless the

failure to repurchase can be explained by, for example, a sharp increase in

the price immediately after the announcement). If so, a repurchase

announcement might represent an implicit commitment by managers to

repurchase shares unless circumstances would make such a repurchase

undesirable. However, 25% of firms announcing repurchases do not



113 See Ikenberry & Vermaelen, supra note, at 10.

114 See id.; Clifford P. Stephens & Michael S. Weisbach, Actual Share Reacquisitions in

Open-market Repurchase Programs, 53 J. Fin. 313 (1998). To be sure, there might be a good

reason for not explicitly committing to repurchase a specific number of shares. Were the

stock price to shoot up unexpectedly after a repurchase announcement, the firm might

find itself obligated to buy back shares for more than the shares are worth. However, if

managers wished to use a repurchase for credible signaling, they could attempt to solve

this problem. For example, managers could make the repurchase commitment

conditional on the stock remaining below a certain target price. Managers’ failure to try

to use repurchase announcements to make more binding commitments to repurchase

stock suggests either that managers have no interest in using repurchases for credible

signaling or that repurchases are inherently unsuited for this purpose.

115 See Maxwell and Stephens, at 6 (other paper says 30%).





- 44 -

repurchase a single share.116 It is highly unlikely that, in most of these cases, a

sudden change in conditions immediately after the repurchase

announcement thwarted managers’ intention to repurchase shares. Thus, as

other researchers have also concluded, repurchase announcements cannot be

considered credible commitments to repurchase shares.117

Not only do managers announcing repurchases fail to commit to

repurchase shares, they also fail to commit to retain their own shares.

Consequently, even if there were an explicit or implicit commitment by the

firm to repurchase shares, the repurchase announcement would not be a

credible signal of underpricing. Indeed, managers often sell shares in the

market around a repurchase. Managerial share ownership (as a fraction of

outstanding shares) actually declines around as many repurchases as it

increases. In fact, at least one study reports that both mean and median

insider ownership (as a percentage of outstanding shares) drop around the

time of repurchases.118 This decline in insider ownership means that in at

least 50% of repurchases, managers sell more shares in the market than they

indirectly buy through the repurchase.119



3. The Availability of Other (Better) Mechanisms for “Credible”

Share-Value Signaling



Credible share-value signaling is unlikely to require the use of a

repurchase.

There are two other, more simple mechanisms that can achieve the

same result. First, managers could simply pledge to retain all of their shares

until the good news emerges. Second, managers could purchase shares

directly from the corporation at the market price and retain those shares

along with the remainder of their shares until the good news emerges.









116 See Bhattacharya & Dittmar, supra note, at 4.

117 See Ikenberry & Vermaelen, supra note, at 9-10.

118 See Nikos Vafeas, Determinants of the Choice between Alternative Share Repurchase

Methods, 12 J. ACCT. AUDITING & FIN. 101, 112-13 (1997) (finding that following 156

OMRs from 1985 to 1991, mean and median insider percentage ownership dropped

from 15.7% to 15% and 8.7% to 7.7%, respectively).

119 One could argue that there might be an implicit commitment not to sell shares

in firms that have trading windows, which require managers to hold their shares for 3

months (or longer, if the next window doesn’t open). But even when trading windows

are closed managers often get permission to sell. See Carr, Bettis; Roulstone. Also,

abnormal returns following manager trades tend to last up to 12 months suggesting that

good news takes longer to emerge. Seyhun(?).





- 45 -

a. Simple Pledge to Retain Shares



Credible share-value signaling could be accomplished by managers

pledging to retain existing their shares until their private information

emerges.120

In short, there is no need to incur the administrative expense of a

repurchase (and perhaps distribute cash that is better invested in the firm) to

send a credible signal that the stock is underpriced.

To be sure, one could argue that if managers also pledged to conduct

a repurchase, they would send a ―stronger‖ signal that the stock is worth at

least the repurchase price. The signal would be even stronger because the

cost of false signaling would be higher. The managers would not only give

up the ability to sell their current shares for the current price; they would

also (indirectly) purchase additional shares at an inflated price. However,

repurchases target on average only 7% of a firm’s shares.121 A repurchase

therefore increases the cost to managers of false signaling by a relatively

small amount. It is highly unlikely that this additional cost would make the

difference between credible and non-credible signaling.122

The advantage of this mechanism is that if the managers wish to

signal – and we saw earlier that they generally won’t wish to signal in this

manner and never in fact do -- it does not require that the firm distribute

cash.









120 Returning to the preceding example, suppose that in January the market knows

that the value of ABC Corporation’s stock is either $5 or $15 per share and that by June

the market will know the correct value. Suppose that in January, when the stock is

trading at $10, managers learn that the actual value is $15. The managers could then

pledge to retain their shares until June. If the stock were in fact worth $5 per share, the

pledge to retain their shares would deprive managers of the ability to sell the stock for

$10 per share before the bad news emerges in June and it becomes clear that the stock is

worth only $5 per share. Thus, if the stock were worth $5 per share, the pledge to retain

their shares would impose a cost on the managers of $5 per share. If, on the other hand,

the stock were worth $15 per share, this pledge would not impose a cost on the

managers. Thus, the pledge to retain shares credibly signals that the stock is actually

worth $15, and after such pledge is made, the price should rise to $15.

121 See supra note.

122 One situation in which acquiring additional shares might be useful for signaling

is that in which the insider is anyways prevented from selling his shares – say, because

of a lock up agreement. In that situation a pledge to retain shares sends no information

about managers’ beliefs about the stock, but the indirect acquisition of shares through a

repurchase would provide such information. I thank Steve Choi for pointing this out to

me.







- 46 -

b. Managers Could Buy Stock from Firm at Market Price



To the extent one believes that a repurchase makes a more credible

signal than a pledge to retain shares because the repurchase forces the

managers retaining their shares to ―buy‖ their pro rata fraction of the shares

repurchased by the firm, one might not think that a pledge to retain shares is

an adequate substitute for a repurchase.

If so, the managers could buy the amount of shares that is equivalent

to the amount that they would indirectly buy through a repurchase. Thus if

the managers owned 100 shares, and they were to repurchase 7% of the

firm’s shares in the repurchase, they could simply buy 7 additional shares.

They could buy the shares directly from the firm or in the market.

Like the simple pledge to retain shares, this mechanism decouples the

payout from the signal, enabling managers to signal even when the firm’s

cash is better invested in the firm than distributed to shareholders.



C. Transaction Cost Savings



A third potential benefit of repurchases is that they might reduce

transaction costs borne by shareholders. In particular, if all shareholders

receive a dividend, those who are seeking liquidity (for consumption or

investment in other securities) will get what they want: cash. But those not

seeking liquidity will be forced to incur transaction costs reinvesting the

dividend in the stock of the issuing (or another) firm. With a repurchase,

those shareholders who do not seek liquidity can just sit still, incurring no

costs. Those who need cash sell the stock, which they might have needed to

do even had the firm issued a dividend.

As this Section explains, however, the transaction costs associated

with repurchases can be higher or lower than dividends, depending o the

parameters. And any transaction cost benefit achieved with repurchases

could easily be accomplished with dividends and dividend reinvestment

plans.





1. The Potential Benefit





If all shareholders receive a dividend, then those who are seeking

liquidity (for consumption or investment in other stock) will get what they

want: cash. But, in the absence of a dividend investment plan, those not

seeking liquidity will be forced to incur transaction costs reinvesting

dividend in the stock of the issuing firm. With a repurchase, those

shareholders who do not seek liquidity can just sit still, incurring no







- 47 -

transaction costs. Those who need cash can sell stock, which they would

need to do anyway (unless the dividend that would have been issued in

place of the repurchase would have provided them with sufficient cash).123

But any benefit provided by repurchases is likely to be small. First,

90% of share repurchases are conducted by firms that also issue dividends. 124

If dividends imposed meaningful transaction costs on these shareholders, the

shareholders would either (a) ask managers to convert the dividends into

repurchases or (b) sell their shares and buy the stock of firms not issuing

dividends.

Second, share repurchases are used to distribute transitory cash flows

and are done only once or twice every 5 years. These repurchases could be

replaced by large special dividends, which are very different from getting

the small dividends every quarter. Thus, even if some investors might prefer

repurchases over small quarterly dividends, those investors might not prefer

repurchases over a special dividend.

Third, large institutional investors, which own approximately 50% of

publicly traded shares, continually need cash for redemptions and operating

expenses and are thus likely not to be find dividends inconvenient.





2. The Potential Transaction Cost Disadvantage of Repurchases



Not only are the potential transaction cost benefits of repurchases

likely to be small, they might even impose net costs. First, repurchases

impose trading costs that dividends to not. In particular, shareholders

selling their shares must incur brokerage trading commissions are subject to

a bid-ask spread. For those shareholders who want cash, dividends would

therefore reduce transaction costs. Second, if the percentage of shareholders

seeking liquidity is high enough, a repurchase might well reduce transaction

costs, even putting aside the issue of brokerage commissions and the bid-ask

spread. Suppose, for example, that 60% of shareholders would like liquidity,

and that the special dividend the firm would issue in place of a repurchase

would satisfy their liquidity needs; the remaining 40% wish to increase their

investment in the firm. And suppose that every shareholder will receive the

special dividend. In that case, the special dividend would allow 60% of the

shareholders to get cash without selling their shares, and 40% would be

forced to take their dividend and reinvest in the firm’s shares. If there is a

share repurchase, 60% of the shareholders must sell shares, and only 40% can

sit still.







123 See Elton and Gruber, supra note x.

124 See Grullon and Michaely (2000), supra note x, at 7.





- 48 -

3. Dividend Reinvestment Plans Can Achieve the Same Benefit





Even if the transaction cost benefits of repurchases exceeded their

costs, dividends along with dividend reinvestment plans could achieve the

same benefit as repurchases. A dividend reinvestment investment plan

allows shareholders who would otherwise receive a dividend to be given an

equivalent amount of stock instead. These plans are generally used by

individual shareholders who wish to avoid the transaction costs associated

with reinvesting the small dividends they get quarterly. They are especially

popular among individual investors with relatively small shareholdings in

any given firm. To the extent that such shareholders also prefer repurchases

to special dividends they could use these plans for special dividends as well.

This would eliminate transaction costs for non-liquidity seeking

shareholders.



D. Funding Stock Option Plans



Some market observers have suggested that repurchases are necessary

to ―fund‖ employee stock option plans. These plans give employees options

to buy stock, exercisable against the firm when the options vest. Thus the

firm needs shares to satisfy these options. However, as I explain below,

there is no need for firms to buy stock on the open market to maintain their

employee stock option plans.



1. The Potential Benefit



Employee stock option plans have become increasingly popular. Most

of the top management’s compensation now comes in the form of stock.

Under these plans, employees are given options on the firm’s stock at a

certain strike price (usually equal to the market price on the date of grant).

The options cannot be exercised until the end of the vesting period. When

they are exercised, the firm must give the employees shares. The employees

will then typically sell their shares in the market.



A repurchase provides a benefit by allowing the firm to buy shares in

the market, over time, which they can use to ―fund‖ these option programs.

Indeed, there is some evidence of a connection between the use of

repurchases and these programs. In particular, the number of shares

repurchased by firms is correlated with the number of exercisable employee

options.125 And about 50% of repurchased shares are recycled through





125 See Kahle, supra note x, at 5. Weisbenner (2000) finds that total options

outstanding is correlated with repurchase activity (clarify); Kenneth J. Klassen and





- 49 -

option programs.126





2. The Dispensability of Repurchases



However, repurchases are not necessary for stock option plans. In

fact, a considerable number of firms maintain such plans without buying

back a commensurate amount of stock. They do this by issuing additional

shares. Alternatively, a firm that prefers not to issue additional shares can

employ share appreciation rights (SARs), phantom stock or other incentive

devices that do not require the use of actual shares.





VI. THE DESIRABILITY OF REPURCHASES WHEN STOCK DEMAND

CURVES SLOPE DOWNWARD



We have seen that, by coupling a redistribution to a dividend,

repurchases can create various distortions – including underinvestment,

cash-hoarding, and reduced disclosure. We have also seen that the benefits

commentators attribute to repurchases – financial flexibility, signaling,

funding option plans, and reduced transaction costs – can be achieved either

with dividends alone or with a much simpler and cheaper mechanism than

repurchases.

Throughout the discussion we have assumed implicitly (wherever it

was relevant) that the market price of the stock reflects everyone’s best

estimate of the value of the stock. Thus the only way that a repurchase could

affect the stock price is by affecting investors’ estimate of the value of the

stock, either through an efficiency effect or an informational effect. A

repurchase can affect this estimate in two ways. First, by changing the actual

value of the stock – for example, by distributing excess cash (the efficiency

effect). Second, when the public does not have complete information about

the value of the stock, by providing additional information to the market that



Ranjini Sivakumar, Stock Repurchases Associated with Stock Options do Represent Dollars out

of Shareholders’ Wallets (working paper, 2001)(finding that total options outstanding can

explain repurchase activity) Cf Jolls (1998) (finding no evidence that total options affect

likelihood of repurchase)(check).

126 Some economists have suggested that firms issuing stock to executives

exercising options are in effect engaging in a small equity offering. This decreases the

firm’s leverage. Thus, a repurchase can be used to increase the firm’s leverage back to its

desired level. See Grullon and Ikenberry (2000). However, as Part III.B. explained, a

repurchase has the same effect on leverage as a dividend that distributes the same

amount of cash. Thus, repurchases are not necessary to maintain the correct leverage

even if the firm is issuing stock to its executives.







- 50 -

causes the market to change its estimate of the value of the stock (the

informational effect). For example, if managers are more likely to announce a

share repurchase when the stock is underpriced than when it is overpriced,

such an announcement will cause the market to revise upwards its estimate

of the value of the stock and bid the price up, even if it has no effect on the

underlying value of the stock.

We now consider another mechanism through which a repurchase

might be able to affect the stock price, even if only temporarily: by changing

the marginal shareholder. As I explain below, there is considerable evidence

that shareholders do not hold the same estimate of the value of a particular

stock. Some shareholders value it more than others. And at any given point

in time, the market price reflects what the marginal (lowest-valuing)

shareholder is willing to sell his shares for. Those shareholders who value

the stock higher will not sell at that price; those who value the stock will less

will have already sold their shares. The dispersion of values suggests that a

firm might be able to boost the price of its stock, at least temporarily, by

repurchasing shares from its lowest-valuing shareholders.

I want to make clear at the outset that I am not claiming that, as an

empirical matter, firms are able to permanently or even temporarily boost

the price of their stock simply by buying back their shares, even in the

absence of efficiency and informational effects described above. Rather, the

purpose of this Part is to describe the additional problems that are likely to

be associated with repurchases IF repurchases could boost the stock price

simply by reducing the number of shares. In doing so, I will consider two

possible cases: (1) that in which the repurchase can temporarily boost the

price of the stock until the market re-equilibrates (―temporary price

pressure‖); and (2) that in which the repurchase can permanently boost the

price of the stock (―permanent price pressure‖).

As I will explain, when repurchases can boost the stock price simply

by taking stock out of the hands of the lowest-valuing shareholders,

managers’ ability to conduct repurchases can lead to further distortions. In

particular, managers will have an incentive to use repurchases to boost the

stock price before selling their shares. This in turn will give rise to

distortions similar to those that arise when managers use repurchases to buy

stock at a low price. First, managers intending to sell shares might have an

incentive to repurchase shares to boost the stock price when from an

efficiency perspective the cash should be left in the corporation. Second, if a

repurchase cannot permanently boost the price of the stock by changing the

marginal shareholder, managers not intending to sell shares until some point

in the future might delay distributing cash that should otherwise be

distributed in order to provide them with cash to buy back shares from low-

valuing shareholders shortly before selling their own.







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The remainder of this Part proceeds as follows. Section A describes

the evidence suggesting that stock demand curves are temporarily or

permanently downward sloping and that repurchases can boost the stock

price, either temporarily or permanently. It also explains why stock demand

curves might be downward sloping. Section B describes the redistributional

effects of repurchases when they boost the stock price by changing the

marginal shareholder. Section C then describes the two distortions that can

result from the use of repurchases for this purpose.



A. The Possibility of Downward Sloping Stock Demand Curves



Until now the analysis has assumed that the stock price reflects the

market’s single shared estimate of the value of the stock. Thus, there is only

one way to affect the price of the stock – to change the market’s estimate of

its value. Accordingly, a repurchase could affect the stock price only either

by changing the value of the underlying stock – by, for example, improving

or worsening the leverage of the firm (an ―efficiency effect‖), or when the

market lacks all of the relevant information about the value of the stock, by

communicating information about that value to the market (whether or not

the repurchase changes the underlying value itself (an ―informational

effect‖). So, for example, if managers on average announce repurchases

when the stock is underpriced, then a repurchase announcement would

signal that, on an expected value basis, the value of the stock is higher than

was previously thought by the market. Importantly, I have assumed that

one cannot increase the price of the stock merely by buying shares. Put

differently, one could buy an unlimited number of shares without affecting

the stock price, as long as the repurchase has no informational or efficiency

effects. For quite some time, this has been the conventional view among

finance economists (and many law and economics commentators).127

However, over the last 10 to 15 years empirical studies have led many

economists to believe that one can affect the stock price, at least temporarily,

simply by buying or selling shares. 128 Under this view, at least in the short





127 See, e.g., Frank H. Easterbrook & Daniel R. Fischel, The Proper Role of a Target’s

Management in Responding to a Tender Offer, 94 HARV. L. REV. 1161, 1165-68 (1981).

128 For contributions to the empirical finance literature on the elasticity of supply

and demand for publicly traded shares, see generally Laurie Simon Bagwell, Shareholder

Heterogeneity: Evidence and Implications, 81 AM. ECON. REV. 218 (1991); Claudio Loderer et

al., The Price Elasticity of Demand for Common Stock, 46 J. FIN. 621 (1991). David T. Brown

& Michael D. Ryngaert, The Determinants of Tendering Rates in Interfirm and Self-Tender

Offers, 65 J. BUS. 529, 530 (1992); Lawrence Harris & Eitan Gurel, Price and Volume Effects

Associated with Changes in the S&P 500 List: New Evidence for he Existence of Price Pressures,

41 J. FIN. 815 (1986); Andrei Shleifer, Do Demand Curves for Stocks Slope Down?, 41 J. FIN.





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run, firms can drive up the price by repurchasing shares, even in the absence

of efficiency and informational effects.129

Buying or selling shares affects the stock price if the demand curve for

shares, like the demand curve for most other goods, is downward sloping.

At a lower price, more investors are willing to buy and hold stock. In order

to get investors to hold a certain number of shares, the price must be set

appropriately low. In order to get investors to hold more stock, the stock

must be offered at an even lower price. As the price rises, the shareholders

who value the stock the least will be induced to sell their shares. The higher

price that is offered, the more shareholders will sell their shares. Thus, to buy

an increasing amount of shares, one must offer a higher and higher price. In

other words, there is an upward-sloping supply curve for stock. Because our

interest is on the effect of repurchases on the effect of the stock price (rather

than the effect of secondary equity offerings), we will focus on the dynamics

of buying back shares from shareholders rather than selling additional shares

to shareholders, and thus refer to the upward sloping supply curve.

The price at which a seller is willing to sell a good is called his

―reservation value.‖ The market price (at which one can sell a share) is,

therefore, the reservation value of the lowest-valuing (or marginal)

shareholder. Shareholders with higher reservation values are not willing to

sell at the market price. Those with lower reservation values will already

have sold their shares.

There are a number of possible explanations for the dispersion of

reservation values among shareholders – or ―shareholder heterogeneity.‖

Shareholders may have different transaction costs or varying tax





579 (1986). For contributions to the theoretical literature, see Robert Jarrow,

Heterogeneous Expectations, Restrictions on Short Sales, and Equilibrium Asset Prices, 35 J.

FIN. 1105 (1980); Joram Mayshar, On Divergence of Opinion and Imperfections in Capital

Markets, 73 AM. ECON. REV. 114 (1983).

Some of the best evidence of the imperfect elasticity of shareholder supply

comes from shareholder tendering patterns in RTOs. In almost all fixed price RTOs,

some shareholders tender and some do not, indicating that many shareholders are

unwilling to sell even at what is usually a substantial premium over the pre-offer price.

See Comment and Jarrell, supra note, at 1257 (reporting an average tendering rate of 25

percent for 65 fixed price RTOs from 1984-89). And in Dutch auction RTOs,

shareholders typically tender along the entire price range, evidence that to purchase

more and more shares one must pay an increasingly higher price. See Bagwell, supra

note __, at 72.

129 For a long time this has also been accepted wisdom in the markets, not only in

the US but also abroad. See Business Recorder, 2001 WL 3348266 (2/4/2001) (reporting

that Toyota sought permission to buy back a large number of shares in order to reduce

the supply and thereby boost the stock price).







- 53 -

situations.130 Shareholders may have asymmetric information about the value

of the stock. Finally, shareholders may have the same information about a

stock but nevertheless form heterogeneous expectations about its future

performance.131 Whatever the source(s) of shareholder heterogeneity, the

important point is that the shareholder supply curve slopes upwards.

Given an upward-sloping supply curve, a firm repurchasing its shares

takes those shares out of the hands with those whose reservation values are

at or below the repurchase price, leaving shares in the hands of those whose

reservation values are higher. The shareholders remaining after the

repurchase will, therefore, tend to have higher reservation values than the

pre-repurchase shareholders.132 Most importantly, the post-repurchase

marginal shareholder -- the shareholder with the lowest reservation value

after the repurchase -- should have a higher reservation value than that of

the pre-repurchase marginal shareholder. 133 Everything else equal, a

repurchase could increase the trading price of the stock through this ―price

pressure‖ effect. 134

To be sure, a repurchase is not identical to a third party purchasing

the firm’s shares. When a third party purchases a share from a current

shareholder, the firm itself is unaffected, and the intrinsic value of the share

is unaffected. Thus the purchase should not affect shareholders’ reservation

values. But when the firm repurchases its own shares, both the value of the

firm and the value of each remaining share change: the firm reduces its value

by paying cash for its own stock and each remaining share now has a claim

to a larger fraction of the that lower value. Thus, the repurchase itself could

affect shareholders’ reservation values during the repurchase by changing

the underlying value of each share. However, I will assume for purposes of



130 See Lakonishok and Vermaelen, supra note, at 459; Gay, Kale, and Noe, supra

note, at 63-66. There is evidence that differences in public shareholders’ tax costs from

tendering make tendering on an after-tax basis worthwhile for some shareholders but

not for others. See Brown and Ryngaert, supra note, at 530.

131 See Stout, supra note x, at ________; Booth, supra note x, at _____. One might

think that the shareholder with the highest reservation value would buy out all of the

shareholders with lower reservation values at a mutually agreeable price. However,

because of risk aversion, liquidity constraints, transaction costs and taxes, a

shareholder’s selling reservation value is likely to be higher than his buying reservation

value. See Brown and Ryngaert, supra note, at 529 (examining determinants of

shareholder reservation values); Stout, supra note x, at _____. See Gerald D. Gay, Jayant

R.Kale, and Thomas H. Noe, Share Repurchase Mechanisms: A Comparative Analysis of

Efficacy, Shareholder Wealth, and Corporate Control Effects, Fin. Mgmt. 44,46 n.9 (1991).

132 See Booth, supra note x, at 1089 (observing that open market share repurchases

put upward pressure on the price by eliminating the lowest-valuing shareholders).

133 Cf. Bagwell, supra note, at 72-73 (describing evidence that Dutch auction RTOs

change the marginal shareholder).

134 See Dittmar, supra note, at 335.





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this Part that even after such an adjustment shareholders’ reservation values

continue to be dispersed in a way that permits the firm to boost the stock

price by repurchasing shares . This is likely to be the case at least until the

market learns that the firm has been buying its own shares, which might take

months or even a year from the time the repurchase begins.



B. Managers’ Use of Repurchases to Sell at a Higher Price





We saw in Part IV.A. that managers can -- and do -- use the

redistributional effect of repurchases to transfer value to themselves and

remaining shareholders by repurchasing shares when the actual value of the

stock exceeds the stock price. Because market participants are not unaware

of this fact, market participants are likely to infer from a repurchase

announcement that the stock may be underpriced, and bid up the price of the

stock upon hearing a repurchase announcement. 135 This, in turn, suggests

that managers intending to sell shares might announce a repurchase in order

to boost the price of the stock before selling the shares, even if they have no

immediate intention of repurchasing any shares.

We now turn to consider how upward sloping supply curves for stock

might provide another means by which managers can transfer value to

themselves from public shareholders. If supply curves for stock slope

upwards, then managers intending to sell shares can use repurchases

themselves to boost the market price of the stock, at least temporarily, before

selling their shares. Thus by announcing a repurchase and then actually

repurchasing shares, managers can boost the stock price not only by

implicitly signaling that the stock is underpriced but also by buying shares

from the lowest-valuing shareholders.

As also noted in Part IV.A., an important limit on managers being able

to use repurchase announcements to boost the stock price is that, for various

reasons, managers cannot announce a repurchase every time they wish to

sell stock. For example, managers cannot announce a new repurchase until

they have completed the previous repurchase program, which might take

months or even years. But to the extent the firm has cash that can be used for

buying back stock, managers can always repurchase stock shortly before

selling their shares. Thus, upward sloping supply curves would increase not

only the magnitude of the price boost that managers can achieve using

repurchases and repurchase announcements but also the frequency with



135 As noted above, there are other reasons that market participants might react

favorably to a repurchase announcement besides the signal it sends about the actual

value of the stock. For example, investors might bid the price up because they believe

the firm will distribute excess cash that it had been holding and that was earning poor

returns.





- 55 -

which repurchases can be used to boost the stock price before selling.

As noted in Part IV.A, managers are frequent sellers of shares. Most

managers receive a substantial portion of their salary in the form of stock

options that give them the right to purchase the corporation’s shares at a

discounted price. Although managers may decide to hold the purchased

shares in their portfolios, they will frequently sell the stock acquired by

exercising the options. 136

Managers sell shares for a number of different reasons. They may

wish to diversify their holdings. They may have liquidity needs. Or the

managers may know ―bad news‖ and wish to sell before that news emerges

and drags down the stock price. 137 Regardless of the reason, once the

managers have decided to sell shares, they will wish to sell those shares at

the highest possible price. And managers thus have an incentive to use

repurchases to buy back shares from the lowest-valuing shareholders and

thereby boost the stock price before selling their own shares.

It should be noted that managers, to the extent that they continue to

own shares in the firm, have an incentive not to reduce the value of those

shares by buying stock that is overpriced. Thus in deciding whether to

repurchase shares to boost the stock price, they will take into account not

only their ability to boost the stock price but also the effect of the repurchase

on their remaining shares. If managers are selling most of their shares

however, then the actual value of the shares being repurchased is not as

relevant.

We saw earlier that there is evidence consistent with the use of

repurchase announcements to boost the stock price before managers sell

shares: at least one study reports that mean and median insider percentage

ownership fall around the time the repurchase is announced. Because firms

generally do not report when they actually repurchase shares, there is no

similar study examining the relationship between insider ownership (or

sales) and actual repurchases. However, to the extent that there is a

correlation between repurchase announcements and repurchases, this

evidence is also consistent with the use of repurchases themselves to boost

the stock price before managers sell their shares.







136 In fact, managers of publicly traded corporations sell approximately twice as

much of their own corporation’s stock as they buy. ________Seyhun, supra note x, at

194; _________Rozeff and Zaman, supra note x, at 42. See H. Nejat Seyhun, The

Effectiveness of Insider Trading Sanctions, 35 J.L. & Econ. 147, 158-60 (1992).

137 For an explanation of the limited effect insider trading laws have on managers’

ability to trade on inside information, see supra Part IV.A.1.b. For a summary of

empirical studies finding that managers sell before the release of bad news, see Fried,

supra note, at 317-20.





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C. Potential Distortions



Having seen the distributional effects of the price pressure induced by

a repurchase, it is now time to consider the additional distortions that can

arise if a repurchase can be used to generate such price pressure. We first

examine managers incentive to use price pressure to boost the stock price.

We then examine the two distortions that can result from the use of price

pressure to boost the stock price: (1) underinvestment and (2) cash hoarding.



1. Underinvestment

[TBA]



2. Cash-Hoarding



Managers might have an incentive to use repurchases to delay

distributing cash through a repurchase until shortly before they plan to sell

their shares. Note that managers might have an incentive to delay

distribution even if a repurchase generates a permanent price pressure effect

because, to the extent that they will be given options during the intervening

period, which are usually set to the grant-date market price, they wish to

keep the price low. Indeed, there is evidence that managers manipulate the

release of news by accelerating the release of bad news and delaying the

release of good news to lower price around the time they are granted.





VII. INFERRING THE DESIRABILITY OF REPURCHASES FROM THE WORLD

AROUND US



Part IV identified several potential efficiency costs associated with the

use of repurchases – underinvestment, cash-hoarding, and reduced

disclosure. In Part V we examined various benefits of a repurchase and saw

that they could easily be replicated by a dividend or another, simpler

mechanism.

In this Part, I want to consider whether there is any empirical

evidence that, notwithstanding the analysis in Parts IV and V, share

repurchases are desirable. Section A considers two empirical regularities

that might suggest that repurchases are desirable (1) that share repurchase

announcements tend to boost the stock price; and (2) that firms fail to

prohibit repurchases in their charters – which might be expected if

repurchases were undesirable. Section B considers empirical evidence

suggesting that repurchases are an inferior method of distributing cash – the

fact that many firms continue to use dividends notwithstanding their tax

disadvantages.





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A. Is there Evidence in Favor of Repurchases?







1. The Stock Price Reaction to Repurchase Announcements



As noted in Part II, the market reacts positively (on average) to OMR

announcement. The market reaction is strongest if the announcement is the

first in 5 years: _____, and gets progressively weaker each successive

announcement_________. One might infer from the favorable stock market

reach to repurchases that repurchases are socially desirable. But this

inference is not warranted.

First, I will show that the market price could increase even if the

repurchase signaled by the announcement is expected to destroy value ex

post, say, by distributing needed cash. Second, to the extent some of the

harms of a repurchase occur ex ante, such as cash-hoarding (under-payout of

cash), these harms will not be reflected in the stock price reaction to

repurchase announcements ex post. Thus even if the stock price

announcement signaled that the repurchase is expected to be value-creating

ex post, one could not conclude that the anticipated repurchase is overall

value-creating. Third, even if (a) repurchases created value ex post and (b)

did not destroy value ex ante, the positive stock market reaction to their

announcement would still not establish their desirability because the

alternative to the repurchase is not necessarily retaining the cash but rather

distributing it as a special dividend.



a. Price-boosting repurchase can destroy value ex post



I will now explain why one cannot infer that a repurchase is value-

creating ex post simply because its announcement causes the stock price to

rise or because the stock price rises after the firm actually repurchases shares.

The reason that the stock price reaction to a repurchase announcement

or to the repurchase itself cannot be used to infer the ex post efficiency effects

of the repurchase is that the stock price increase could result in large part

from factors that have nothing to do with the ex post efficiency of the

repurchase.

Recall that a repurchase can affect ex post value in two ways: (1) by

moving capital from corporate investments to projects outside the

corporation and (2) by altering leverage. If the stock price reaction reflected

only these two effects, and the stock price reaction were positive, we could

infer that repurchases tend to be value-creating ex post.

But the stock price rise could be generated by factors that have

nothing to do with value creation: (1) expropriation of value from creditors;





- 58 -

(2) signaling effects, or (3) in the presence of downward sloping demand

curves for stock, price pressure.



1. Expropriation of Creditors



Until now the analysis has assumed for simplicity that a repurchase

affects only shareholders – and thus that a repurchase’s effect on shareholder

value is the same as its effect on social value. However, in examining the

stock market’s reaction to repurchase announcements we must take into

account the possibility that – in the real world – a repurchase does affect the

value available to parties other than the shareholders.

In the real world, a repurchase can affect the firm’s creditors. In

particular, a repurchase, like a dividend of the same amount, can transfer

value from creditors to shareholders. Any distribution of cash by the

corporation might transfer value from creditors to shareholders by (a)

reducing the amount of assets that are available to pay their claims in the

event of default; and (b) increasing the amount of cash that will have been

received by shareholders should the firm later fail.138

To be sure, if the likelihood of default is zero after the cash

distribution, then a distribution does not transfer any value. The money

would have gone to the shareholders in any event. However, even the most

stable firms have a nonzero probability of default. In fact, there is evidence

that on average both repurchases and dividends do transfer value from

creditors to shareholders.139

To the extent a repurchase is expected to transfer value from creditors

to shareholders, its announcement will increase the expected cash flow to

equityholders and therefore boost the stock price. Thus, part of the market’s

positive reaction to repurchases could be due to the expected transfer of

value from creditors to equityholders. This transfer, and the stock price

generated in expectation of this transfer, do not reflect the creation of social

value, but rather the shifting of value from one set of claimants on the firm’s

cash flow to another. To the extent the stock price increase reflects this

expected transfer of value, the market’s reaction to the repurchase

announcement does not signal that the repurchase is ex post efficient.



138 A repurchase/dividend can also hurt creditors by increasing the probability of

financial distress and failure to the extent that it reduces the cash reserves of the firm.

This, of course, provides no offsetting benefit to shareholders.



139 See e.g., William F. Maxwell and Clifford P. Stephens, The Wealth Effects of

Repurchases on Bondholders (working paper, 2001) (finding evidence of wealth

transfer); Upinder Dhillion and Herb Johnson, The Effect of Dividend Changes on Stock

and Bond Prices, 49 J. Fin. 281 (1994)(finding evidence that large dividends transfer

wealth).





- 59 -

In fact, the announcement might boost the stock price even if

shareholders expect the repurchase to reduce total value by, for example,

distributing cash that would earn a higher return for the corporation.

Suppose, for example, that in expectation the repurchase that is announced

will destroy $1 of value per share, but at the same time transfer $3 per share

from creditors to equityholders, so that equityholders expect to gain $2 per

share. Equityholders would react to the announcement of such a repurchase

by bidding up the price of the stock, even though the total amount of value

available will, in expectation, decrease as a result.



2. Incidental Signaling



A second reason why stock pre announcements might boost the stock

price even if the repurchase itself is not expected to increase social value or

even increase the value available to shareholders value is that the repurchase

announcement signals that the stock is likely to be underpriced. For now,

suppose that repurchases do not have any efficiency effects or transfer value

from creditors. Repurchase announcements could still boost the stock price

to the extent they reveal that expected share value exceeds the stock price

(that is, they reveal the stock is likely to be underpriced). Repurchase

announcement would communicate that expected firm value exceeds the

stock price if managers are more likely to announce a repurchase when the

stock is underpriced than when it is overpriced (or, on average the stock of

firms announcing repurchases is underpriced).

In fact, managers are more likely to announce a repurchase when the

stock is underpriced. We have seen that managers can use repurchases for

the following two purposes: (1) to indirectly buy stock at a low price for

themselves and remaining shareholders (―indirect buying firms‖); and (2) to

boost the stock price before selling their shares (―selling firms‖).

If all repurchase announcements were motivated by indirect buying

firms and selling firms, and there are equal numbers of both, we would

expect the firms making such announcements to be, on average,

underpriced. Take selling firms. There are three reasons why mangers

might sell: for liquidity reasons, to diversify, or to sell before news comes

out revealing that the stock is underpriced. In those firms where managers

wish to sell for liquidity or diversification reasons, the stock might be

underpriced. Thus sometimes the stock of firms announcing repurchases to

boost the price of the stock will be underpriced, and sometimes it will be

overpriced. In contrast, all of the repurchase announcements by indirect

buying managers will be made by firms whose stock is underpriced. Thus if

the pool of announcing firms is composed equally of indirect buying and

selling firms, there will be more underpriced firms than overpriced firms and







- 60 -

on average these firms are likely to be underpriced.140

In addition, there are likely to be more indirect buying firms than

selling firms. Managers can profit from indirect buying simply by retaining

their shares—that is, without any buying or selling. In contrast, selling firm

managers must be able to sell their shares. And while there are no

constraints on managers’ ability to retain their shares, there are constraints

on managers’ ability to sell their shares. For example, firm-imposed

restrictions on managerial trading might prevent a manager from selling her

shares except during several short ―trading-windows‖ throughout the

year;141 the manager might have a large built-in gain on which she wishes to

avoid paying capital gains tax; or the manager might have purchased shares

at a lower price within the previous six months and thus would face section

16(b) liability were she now to sell her shares. Because there are constraints

on managers selling but no constraints on retaining their shares, there are

likely to be more indirect buying than selling repurchases and this would

cause the pool of announcing firms to be even more underpiced. Thus, a

repurchase announcement is likely to signal that the stock is, in expectation,

underpriced.

To the extent a repurchase announcement signals that the actual value

of the stock is likely to be higher than the pre-announcement market price,

its announcement will cause investors to revise upwards their estimates of

the value of the shares and bid up the stock price. Thus, part of the

market’s positive reaction to repurchases could be due to this ―incidental

signaling‖ effect. The stock price increase due to this signaling effect does

not reflect the creation of social value. Thus, to the extent the stock price

increase reflects this informational effect, the market’s reaction to the

repurchase announcement does not signal that the repurchase is ex post

efficient.

In fact, as with the expropriation of value from creditors, the

announcement might boost the stock price even if shareholders expect the

repurchase to reduce total value by, for example, distributing cash that

would earn a higher return in the corporation. Suppose, for example, that

the repurchase that is announced is expected to destroy $1 of value per share,

but at the same time signals that, everything else equal, the stock is $3 per

share more valuable than was previously thought. In that case,





140 And it is useful for incidental signaling – managers buy low and use

repurchases to diversify, get liquidity, or sell high – so on average the stock is

underpriced. See Grullon and Ikenberry p.38. [They note that the Canadian data is very

similar to the US]



141 See Bettis et al., supra note, at 192.







- 61 -

equityholders would revise upward their estimate of the value of the stock

by $2 per share. Equityholders would react to the announcement of such a

repurchase by bidding up the price of the stock, even though the total

amount of value available will decrease as a result.



3. Price Pressure



Even if a repurchase announcement could not boost the stock price by

signaling a transfer of value from creditors or incidentally signaling that the

stock is likely to be underpriced, the announcement might still be able to

boost the stock price by signaling that there will be a change in the marginal

shareholder. As we saw in Part VI, when stock demand curves are

downward sloping, a repurchase changes the identity of the marginal

shareholder. Thus to the extent that shareholders’ reservation values for the

stock are dispersed, the firm can eliminate lower-valuing shareholders by

buying back stock, and thereby boost the market price. If investors

anticipate that an announced repurchase will change the marginal

shareholder and thereby boost the stock price, they might bid up the price of

the stock in anticipation, changing the marginal shareholder immediately.

Thus, part of the market’s positive reaction to repurchases could be due to

this anticipated price pressure effect. The stock price increase due to

anticipated price pressure, just like those parts due to value-transfer from

creditors and incidental signaling, does not reflect the creation of social

value. Thus, as with these other factors, to the extent the stock price increase

reflects this expected price pressure effect, the market’s reaction to the

repurchase announcement does not signal that the repurchase is ex post

efficient.

As with the value-transfer and signaling effects, the price pressure

effect might cause the announcement to boost the stock price even if

shareholders expect the repurchase to reduce total value by, for example,

distributing cash that would earn a higher return for the corporation.

Suppose, for example, that the repurchase that is announced is expected to

destroy $1 of value per share, but at the same time replaces the old marginal

shareholder with a new marginal shareholder who, everything else equal,

would value the stock at $3 more per share. In that case, investors would bid

up the price of the stock by $2 per share, even though the total amount of

value available will decrease as a result of the repurchase that is expected

following the announcement.



b. Ex Ante Harms



Even if the positive stock price reaction to repurchase announcements

did not reflect a transfer of value from creditors, incidental signaling, or price





- 62 -

pressure, but rather the ex post creation of value, one still couldn’t conclude

that repurchases are socially desirable. The reason is that there are ex ante

(pre-announcement and pre-repurchase) effects of using repurchases to

distribute value, and these effects will not be reflected in the stock price

reaction to the repurchase announcement. Importantly, there could be a large

number of ex ante costs to the use of repurchases. As Part IV.B. explained, to

managers might inefficiently retain funds while waiting for the stock price to

fall below its actual value. The resulting loss of value will not be reflected in

the market’s reaction to the subsequent repurchase announcement. Indeed,

the greater is the inefficiency cost from the cash hoarding, the greater is the

benefit to shareholders from distributing the cash, and the larger the

market’s reaction will be. Thus paradoxically, a large stock price reaction

could mean a large ex ante inefficiency.

If the net ex ante cost of using repurchases to distribute cash exceed

the net ex post benefits, then the stock market will react positively to a

repurchase even when, taking into account both ex ante and ex post effects,

the use of the repurchase to distribute cash destroys value. This is yet

another reason why one cannot conclude from the market’s positive reaction

to repurchase announcements that repurchases are desirable.



C. Comparison with Dividends



Even if the stock price reaction to share repurchases reflected the

creation of value ex post (and not value-transfer, signaling, or price pressure)

and there were no ex ante costs to the use of repurchases, one still could not

conclude from the market’s positive reaction to repurchase announcements

that repurchases were as desirable as dividends without comparing the

efficiency benefits to those of dividends. Interestingly, the stock market’s

reaction to dividend announcements is greater even though they are less tax

efficient142 (although this might be due to the strong signaling effect of

dividends because they imply an ability and commitment to continue paying

dividends indefinitely).









142 There is evidence that the relative tax efficiency of repurchases accounts for

some of the positive response to their announcement. See Clifford Stephens, Open-market

repurchase programs and the effects of the capital gains tax preference (working paper, 1998)

(reporting that abnormal returns observed around the announcement of OMRs declined

as a result of the decrease in overall tax rates and the capital gains tax preference);

Grullon and Michaely (2001), supra note x, at 5 (reporting that the market reaction to

OMR announcements was higher before the 1986 TRA which reduced the differential

between ordinary and capital gainst tax rates)





- 63 -

2. What can be Inferred from the Failure of Corporate Charters to

Prohibit Repurchases?



As we have seen in Parts IV-VII, repurchases are likely to be a less

efficient means of distributing cash than dividends. But if share repurchases

are inefficient, then one might argue assume that investors should be willing

to pay more for shares of firms whose charters prohibit repurchases. The

failure of firms to prohibit repurchases in their charters may thus seem to

demonstrate that repurchases are efficient.143



However, even if managers’ ability to conduct share repurchases is on

balance undesirable for society, it might not be undesirable for shareholders.

In fact, it may well be beneficial to shareholders. To be sure, if share

repurchases are on balance inefficient, shareholders would fully bear the

expected efficiency costs, either directly or indirectly. To the extent the use

of repurchases inefficiently reduced the expected cash flows for equity, these

costs would hurt shareholders directly. To the extent the repurchase

reduced the cash flow to debt, these costs would be borne by the

shareholders through higher interest rates.144



However, as I explained in Part II, repurchases are a much more tax

efficient mechanism than dividends for distributing cash. If this tax benefit to

existing shareholders outweighs the net efficiency costs of share repurchases,

then shareholders would pay a higher price for the shares of corporations

whose charters do not prohibit repurchases.



It should be emphasized that this tax benefit to shareholders does not

increase total value but rather merely transfers value from other parties to

themselves (or, prevents the transfer of value from themselves to other

parties) and leaves the size of the pie unchanged. The tax savings of

repurchases comes at the expense of others who would have received the tax

proceeds or paid less in taxes had the distribution been made as a dividend.

In addition, if demand curves for stock are downward sloping, and

firms can use repurchases to boost the price of their shares by eliminating the

lowest-valuing shareholders, it will be in the interest of shareholders to give



143 For purposes of analyzing the inference that can be drawn from the failure of

corporate charters to prohibit repurchases, I assume that the price paid for shares at an

IPO reflects the contents of the corporate charter. If this is not the case with respect to

restrictions on share repurchases, one clearly could not infer from the absence of such

restrictions in charters that managers= unrestricted ability to conduct share repurchases

is desirable.



144 Except involuntary creditors.







- 64 -

managers the ability to repurchase shares. The reason is that, to the extent

repurchases boost the stock price by altering the marginal shareholder, the

managers can use repurchases to transfer value from buyers to those current

shareholders buying their shares. Although a full analysis of the

distributional effects of repurchases under downward sloping demand

curves is beyond the scope of this project, it can be shown that if managers

repurchase shares only when the actual value of the shares exceeds the

repurchase price, the price-pressure effect of repurchases will

unambiguously transfer value from buying shareholders to selling

shareholders and other remaining current shareholders.

Note that while it might be in the interest of the initial shareholders of

Firm A to permit Firm A’s managers to engage in repurchases in order to

exert price pressure, these shareholders might end up paying more for the

stock of Firm B because of Firm B’s managers’ ability to use price pressure to

boost the price of the stock, and vice versa. Thus investors as a group are

unlikely to benefit from the ability of managers of each firm to exert price

pressure through repurchases.

In sum, because of the tax externality and a potential price pressure

externality, one cannot infer from the absence of restrictions on repurchases

in corporate charters that repurchases are, on balance, efficient.







B. What Does the Use of Dividends tell us?





We have seen that the stock market’s positive reaction to share

repurchase announcements and the failure of firms to prohibit repurchases

in their charters does not provide evidence that managers’ ability to conduct

repurchases is desirable. We now turn to evidence that the use of

repurchases to distribute cash to shareholders might be undesirable – the

continued use of dividends to distribute cash even though dividends are tax-

inefficient.

Although the use of share repurchases to distribute cash has grown

substantially over the last twenty years, approximately 50% of the cash

distributed by US corporations is still distributed by dividends. The failure

of firms to switch entirely to share repurchases suggests that,

notwithstanding their tax inefficiency, there are many shareholders that

prefer having cash distributed through dividends rather than repurchases.

One possible reason for the continued use of dividends is that firms

are reluctant to cut dividends and replace them share repurchases, because a

dividend cut will be taken as a signal that the firm’s managers no longer

believe the firm will have the necessary cash flow to finance the dividends it







- 65 -

had been paying.145 But there is evidence that on average firms cutting

dividends don’t experience abnormal price drops if they have also been

repurchasing their shares.146 In other words, investors appear to believe that

these dividend cuts do not reflect new information about the firm’s expected

cash flow but rather represent managers’ substitution of a more tax efficient

(although perhaps overall less efficient) distribution mechanism for one that

is less efficient. In addition, 20% of firms initiating distributions start by

issuing dividends rather than by repurchasing shares. These firms were not

required to issue dividends to avoid sending a bad signal. 147

One possibility is that much of the demand for dividends comes from

tax-exempt investors (such as pension funds).148 But even if this is the case, it

shows that when taxes are irrelevant, investors prefer dividends.







VII. A NEW APPROACH TO THE REGULATION OF REPURCHASES





This Part proposes and puts forward a change to the regulation of

repurchases that is designed to minimize the efficiency costs that are

uniquely associated with them. Before proceeding, it should be emphasized

that the proposed change would not in any way reduce or undermine the

potential benefits of share repurchases. Thus, even if the benefits attributed

to repurchases – financial flexibility, signaling, funding option plans,

reduced transaction costs – could not easily be replicated (which in fact they

can be), those benefits would not provide a reason for rejecting the proposed

reform.





A. The Proposed Approach: Pre-Repurchase Disclosure



In earlier work I have shown that requiring insiders to disclose their

intended trades in advance would substantially reduce insiders= ability to

engage in insider trading. The reconceptualization offered in this paper

shows that a repurchase is distributionally equivalent to remaining

shareholders purchasing the shares of departing shareholders. The

reconceptualization thus suggests that requiring firms disclose in advance

every intended trade would also reduce managers= ability to indirectly trade



145 DeAngelo et al. Dividends and Losses, 47 J. Fin. 1837, 1862 (1997).

146 See Grullon and Michaely.

147 Admittedly, however, they might have chosen to begin issuing dividends in

order to send a signal that the managers expect future cash flows to be healthy, and

thereby sharply boost the price of the stock (perhaps before selling their shares).

148 See Allen, Bernardo, and Welch.





- 66 -

on inside information. 149

Under the pre-repurchase disclosure rule, a corporation could not

submit an order to its broker to buy its own shares without first giving notice

to the market of the order at least several hours (and perhaps as much as one

business day) in advance. So for example, if the order to the broker is ―buy

1000 shares at $10 or below,‖ the corporation would need to disclose that it

was submitting an order to the broker to buy 1000 shares at $10 or below. . In

the disclosure, the corporation could include any other information that it

wishes to communicate to the market. So, for example, if the firm knew that

it would not be buying more than 5000 shares over the next month, it could

choose to disclose that information as well. The disclosure would be made by

filing details of the order on the SEC's Electronic Data Gathering And

Retrieval system ("EDGAR"), which can make the information available to

the market upon its arrival at the SEC. The firm would then be required to

report the details of the purchase within a few days.

Following the disclosure of an intended repurchase, market

participants could adjust the price at which they are willing to trade to reflect

the heightened possibility of an abnormal price change that is signaled by the

corporation’s order. To see how the rule might work, consider the following

example. Suppose that on Monday, when ABC stock is trading for $10, the

firm announces that, on Tuesday, it will submit an order to buy 20,000 shares

at a price of $11 or lower. Knowing that there is a possibility that the

corporation is buying now because the managers believe, based on inside

information, that the stock is underpriced, market participants who had been

considering trading ABC stock on Tuesday and Wednesday might choose to

modify or abandon their planned trades. Market participants who were



149 An alternative to pre-purchase disclosure would be to require firms

repurchasing shares to adhere to the guidelines set out in Rule 10b5-1 that are designed

to give insiders an affirmative defense to insider trading liability under Rule 10b-5.

Under Rule 10b5-1, there are two such safe harbors that would apply to firms

repurchasing shares. Under the first, the firm would ―specify with precision the

amounts, prices, and dates on which it will repurchase its securities‖, or it may ―use a

written formula to derive amounts, prices, and dates,‖ or it may ―simply delegate all the

discretion to determine amounts, prices, and dates to another person who is not aware

of the material nonpublic information.‖

Under the second, the firm could show that the individual making the decision

to repurchase the shares was not aware of the information and that the firm had

implemented reasonable policies and procedures to ensure that individuals making

such decisions did not violate the laws trading on the basis of material inside

information. See Steven E. Bochner and Leslie A. Hakala, Implementing Rule 10b5-1 Stock

Trading Plans, 15 INSIGHTS 2 (2001)









- 67 -

considering selling shares of ABC stock might not go forward with these

sales, or might increase the price at which they are willing to sell the stock.

Market participants who were considering buying ABC stock might increase

the price at which they are willing to buy it. Market participants who, prior

to the firm's announcement, were not considering buying the stock might

decide to buy shares. The combined effect of these adjustments would be,

everything else being equal, to increase the price at which those making a

market in the stock are willing to buy and sell the stock. When the firm’s

repurchases are executed on Wednesday, it is likely to be executed at a

higher price than if the firm had not disclosed the order in advance--to the

extent that market participants believe that the managers are trading on

inside information.

The prerepurchase disclosure requirement would not be difficult to

enforce. The SEC could easily maintain a record of the prerepurchase

announcements that it receives. Reported repurchases and announcements

could be matched to determine whether any trades had not been preceded

by an announcement.



B. The Benefits of Pre-Repurchase Disclosure



Pre-repurchase disclosure would make it more difficult for managers

to use share repurchases to transfer value from selling shareholders. To the

extent that investors believed that the announced repurchase was intended

to buy stock for remaining shareholders at a low price, the announcement

would cause them to bid up the price of the stock, reducing the value that is

transferred to remaining shareholders. This in turn would reduce managers’

incentives to use repurchases to transfer value in the first instance, which

would also reduce the accompanying distortions – underinvestment, cash-

hoarding, and reduced disclosure.

A potential problem with pre-repurchase disclosure is that managers

might use the disclosure to boost the stock price before selling their stock,

even when the stock is overpriced. To be sure, the managers would then be

forced to indirectly acquire shares at a high price, but they would need to sell

very few of their own shares to give them a net gain. Suppose that the firm

buys back 1000 shares at an inflated price and managers own 5% of the

company. This is equivalent to the managers buying 50 high price shares. As

long as the managers sell more than 50 shares at that same price, they will

profit from the transaction. This problem could be overcome by requiring

managers themselves to announce their trades in advance. Such advance

disclosure would reveal to the market the net direction of managers’ direct

and indirect trades, allowing the market to draw the appropriate conclusion

about the actual value of the stock.

To the extent that demand curves for stock slope downward, the





- 68 -

ability of pre-repurchase disclosure to reduce the resulting distortions is less

certain. If firms can permanently boost the stock price by buying back shares,

pre-repurchase disclosure is unlikely to have much effect. However, if

buying back shares creates only temporary price pressure, then pre-

repurchase disclosure might reduce managers’ ability to use repurchases to

boost the price shortly before selling their shares. If price pressure is only

temporary, this suggests that there are sellers interested in selling their

shares for slightly higher than the current, but it takes them some time to

place their orders. In the meantime, the price remains elevated. Advance

notice of the firm’s intent to repurchase stock might bring those sellers into

the market more quickly, and thereby reduce the period of time in which the

stock price is temporarily elevated.



C. The Costs of Pre-Repurchase Disclosure



[TBA]

1. Financial flexibility

2. Signaling

3. Transaction costs

4. Stock options plan funding





D. Implications for Dividend Taxation and Option Accounting Rules



1. Reduce Tax Subsidy For Repurchases



The analysis of the paper suggests that there is no corporate

governance reason why the tax system should implicitly subsidize

repurchases, and that such a subsidy could in fact give rise to a substantial

cost. Thus an important tax policy implication of this paper is that it would

be desirable, everything else equal, to reduce this subsidy. Although the

question of the optimal tax rate on investment is a complex one that is

beyond the scope of the paper, an implication of the analysis is that no

matter what the rate is, the rate should be the same for dividends as for

repurchases. There are two possible approaches to closing the tax gap

between dividends and repurchases. The first is to tax dividends more like

repurchases. The second is to tax repurchases more like dividends. Below I

consider both types of approaches – including the possibility of eliminating

taxes on both repurchases and dividends.

Completely eliminating the tax distortion in favor of repurchases

would require moving to a consumption tax. However, one could reduce the

distortion either by treating share repurchases more like dividends or vice

versa. For example, one could use the reconceptualization of a share





- 69 -

repurchase put forward in the paper to tax share repurchases according to

their economic substance. Under such a scheme, the selling shareholders

would (as under current law) pay a capital gains tax on the sale of their

shares; the remaining shareholders would be taxed as if they had received a

dividend and their basis in their shares would be increased by the amount of

the dividend. The problem with this approach is that it might get very

complicated, since the composition of shareholders is changing daily and

repurchases occur daily. You would need to attribute dividends to the

correct shareholders.

Alternatively, one could tax dividends at the capital gains rate, and

tax shareholders on dividends only to the extent the dividend exceeds their

adjusted basis in the stock.





2. Accounting: End Discrimination Against Dividend-Protected Options



To the extent that the use of repurchases is driven by an accounting

system that treats options in a way that discriminates against dividends, a

second implication of this paper’s analysis is that it would be desirable to

end such discrimination. The appropriate accounting treatment of employee

options has been a subject of much debate and I have no intention of entering

that debate here. However, if, as it appears likely, the accounting treatment

of options is to be overhauled, a second implication of the paper is that it

should be done in such a way as to level the playing field between dividends

and repurchases.

The accounting bias in favor of dividends that arises in firms using

option compensation could be eliminated either by requiring all firms

granting stock options to managers to record them as an expense, whether or

not they are dividend-protected, or by not requiring firms granting

dividend-protected stock options to record them as an expense.



VIII. CONCLUSION







[TBA]









- 70 -



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