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
Ali Perry
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…
Understanding the Requirements Related to the Use of Non-GAAP Financial Measures
- The SEC continues to scrutinize non-GAAP financial measures, with frequent comment letters on their use. Principal areas of SEC concern, in
Staying on Message: Practical Strategies to Navigate Pre-IPO and De-SPAC Communications
Webinar | September 10, 2025
1:00 a.m. – 2:00 p.m. EDT
Register here.
Join Solebury and Mayer Brown for a webinar on legal, regulatory, and strategic issues arising in connection with offering related communications, especially in connection with an IPO or a de-SPAC transaction. Panelists will offer practical guidance for remaining compliant with securities…
Capital Markets Insight: How to Know When You Need a Temporary CUSIP Number for Reopenings
If you are involved in issuing or trading securities, you are familiar with CUSIP numbers, the nine-digit alphanumeric codes that identify specific securities in the United States and Canada. What you may not know is that sometimes you will need a temporary CUSIP number (also known as a contra CUSIP) in connection with a reopening…

