On December 5, 2025, the Securities and Exchange Commission consented to modifications to the Global Research Settlement applicable to settling firms, which has been in place since the aftermath of the dot‑com bubble bursting. The Settlement contains an Addendum with undertakings that address conflicts of interest between research and investment banking. The Addendum includes a sunset provision providing that new rules would supersede those undertakings. It also states that, for terms that are not superseded, the SEC would agree to amendments or modifications to the Addendum, subject to court approval, unless doing so would not be in the public interest.  The Addendum was modified in 2010 to remove certain provisions.  In the years following entry into the Settlement, FINRA adopted Rule 2241 addressing equity research and, among other things, conflicts of interest. Earlier this year, the settling firms filed motions seeking to terminate the remaining undertakings in the Addendum, given that the FINRA rule addresses conflicts of interest. 

In a statement relating to the SEC’s action modifying the Settlement (see his Statement), Commissioner Uyeda noted that, “It’s not a coincidence that since 2004, there has been a lot less research out of Wall Street, particularly for small and medium-sized companies. The result has been a chilling effect on research coverage in precisely the segments—emerging growth and smaller public companies—where investors most need high‑quality analysis. In 2017, the U.S. Department of the Treasury recommended that the SEC conduct a holistic review of the Global Research Settlement and the research analyst rules to determine which provisions should be retained, amended, or removed, with the objective of harmonizing a single set of rules for all financial institutions.”  There seems to be broad acknowledgment that the regulation and oversight of research requires review.  For example, earlier this year, as part of its review of requirements applicable to member firms, FINRA requested comment on rule modernization, including how its rules affect research analysts and research reports. 

See the release: Global Research Analyst Settlement.