On May 19, 2026, the U.S. Securities and Exchange Commission (the “SEC”) published two rulemaking proposals, each of which would substantially revise the requirements of the U.S. federal securities laws applicable to public companies. These proposals mark the next step in SEC Chair Paul Atkins’ mission to grow the U.S. capital markets and “make IPOs
Ali Perry
Nasdaq Proposes Higher Initial Listing Requirements for SPACs
On April 22, 2026, the Securities and Exchange Commission (“SEC”) filed notice soliciting comments in connection with proposed rules filed April 15, 2026 (SR-NASDAQ-2026-033) by The Nasdaq Stock Market LLC (“Nasdaq”) to raise certain initial listing requirements for special acquisition companies (“SPACs”). The principal change is to raise the size thresholds for initial listing under…
Private Secondary Markets and Sponsored Liquidity Programs
Webinar | April 1, 2026
12:00 p.m. – 1:00 p.m. ET
Register here.
As companies remain private longer, the importance of the private secondary market continues to grow. Well over $60 billion in transactions are being effected through various platforms, and this does not account for other secondary transaction volume.
During this session, representatives…
SEC Leadership Signals Major Digital Assets Developments at ETHDenver
On February 18, 2026, Chairman Paul S. Atkins and Commissioner Hester M. Peirce of the Securities and Exchange Commission (“SEC”) delivered joint remarks at ETHDenver, outlining both the significant regulatory steps the SEC has taken over the past year and its agenda for the months ahead to provide additional regulatory clarity regarding digital assets. The…
SEC Proposes Updates to “Small Entity” Definitions for Funds and Advisers
On January 7, 2026, the Securities and Exchange Commission (“SEC”) proposed amendments to the rules that define which registered investment companies, investment advisers,[1] and business development companies[2] qualify as “small entities” for purposes of the Regulatory Flexibility Act (RFA). These amendments would significantly increase the asset-based thresholds last updated in 1998 and introduce…
SEC Staff No-Action Relief for DTC Pilot Provides a Pathway for Tokenized Securities
On December 11, 2025, the staff of the Division of Trading and Markets of the Securities and Exchange Commission issued a no-action letter to The Depository Trust Company (“DTC”) concerning a pilot version (the “Preliminary Base Version”) of a securities tokenization program, referred to as the “DTCC Tokenization Services.” The letter permits DTC to conduct…
2026 SEC Filing Deadlines and Financial Statement Staleness Dates
This Legal Update summarizes the US Securities and Exchange Commission’s 2026 calendar year filing deadlines and financial statement staleness dates.
Continue reading this Legal Update.
2026 U.S. Annual Report and Proxy Season: It’s Go Time!
Although it may seem early, it is already time to start preparing for the 2026 annual report and proxy season. While many disclosure requirements remain consistent from prior years, there has been a significant shift in the focus of, and discourse relating to, the priorities of the Securities and Exchange Commission. Practitioners started to see…
Preparing for the 2026 US Proxy & Annual Reporting Season: 10-K and Disclosure Trends
Webinar | November 10, 2025
12:00 a.m. – 1:00 p.m. EDT
Register here.
The proxy and annual reporting season may seem a long way off. However, in light of the amount of work and planning that goes into the proxy statement, annual report, and annual meeting of shareholders, this is the ideal time to…
NASAA Amends REIT Guidelines: What Sponsors, Intermediaries, and Investors Need to Know
On September 7, 2025, the North American Securities Administrators Association (NASAA) approved amendments to its Statement of Policy Regarding Real Estate Investment Trusts (the “REIT Guidelines”), which were last amended in 2007. The proposed amendments were last put forth for public comment by NASAA on March 25, 2025.
The REIT Guidelines contain requirements for non-traded…

