Ali Perry

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On September 17, 2026, the Staff of the Division of Trading and Markets (the “Division”) of the Securities and Exchange Commission (the “SEC”) issued two no-action letters addressing the net capital and customer protection implications of “zero cash balance” brokerage account models.  The letters were issued to eToro USA Securities Inc. (“eToro”), an introducing broker…

On September 17, 2026, the Securities and Exchange Commission (the “SEC”) issued an order (Release No. 34-106402; File No. 4-927) granting five-year, temporary exemptive relief allowing (1) qualifying tokenized securities venues that provide innovative automated market makers (“AMMs”) and liquidity pools (together referred to as “AMM Liquidity Pools”) to facilitate trading of National Market System…

On August 24, 2026, the Securities and Exchange Commission (“SEC”) published notice of the filing of a proposal by MEMX LLC to list and trade securities event contracts (File No. SR-MEMX-2026-25).  The securities event contracts would be cash-settled, European-style binary “YES” or “NO” options based on the outcome of an event related to…

On August 18, 2026, the Securities and Exchange Commission (the “Commission” or the “SEC”) published proposed rules, titled “Regulation Crypto Assets” (“Reg Crypto Assets”), which would establish a framework to raise capital and disclosure requirements involving certain crypto asset-related investment contracts.  The proposed rules represent the next phase in the Commission’s ongoing effort to regulate…

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…

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…

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…

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…

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…