Proposed regulations on buy back of shares to hurt genuine shareholders

I disagree with SEBI's proposal of 'tightening' buy back regulations. Here is what they will do (primarily with respect to buy back through open market purchases):

• Having announced buyback - the company must acquire at least 50% of the maximum quantity announced
• The buyback period would be restricted from 12 months to 3 months
• 25% of the money should be kept in escrow
• 2 year cooling off before capital raising again
• 1 year cooling off between two buybacks
• Disclosures enhanced and rationalised
• Monthly disclosures - why proportionate quantity for the month was not bought
• If over 15% of the capital is  sought to be acquired - the open stock market route will be disallowed. 

I don't believe these moves will be good for shareholders. There are two sets of shareholders involved in a buyback. The ones who exit the company by selling/tendering their shares and the one who are left behind as shareholders. The latter group is basically the company itself. The buy back process is a zero sum game, so to the extent departing shareholders gain financially, the ones who continue as shareholders will be hurt. Clearly, the SEBI proposals will hurt those shareholders who have faith in the longer term in the company and people who exit/speculative interests will be benefited.

SEBI needs to do a further analysis before mandating minimum quantity and other restrictions on companies doing buybacks.