Last week, the Securities and Exchange Commission’s Investor Advisory Committee met to discuss, among other things, whether to recommend to the SEC that it issue additional disclosure guidance related to artificial intelligence (AI). With some dissent, the Committee ultimately voted in favor of the recommendations (see Disclosure of Artificial Intelligence’s Impact on Operations)
SEC Consents to Modifications to Global Research Settlement
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
Bringing Back Smaller IPOs?
Earlier this week, Securities and Exchange Commission Chair Atkins gave remarks that provided a perspective on measures intended to promote capital formation. Speaking at the New York Stock Exchange, of course, he noted the now all too familiar statistics regarding the decline in the number of public companies in the United States—from over 7,000 in
SEC Order Delays Compliance Dates for Securities Lending Reporting and Short Position and Short Activity Reporting
Today, the Securities and Exchange Commission issued an order (the “Order”) that provides a temporary exemption from compliance with the short position and short activity reporting rule (Rule 13f-2 and Form SHO reporting) until January 2, 2028. The Order also provides a temporary exemption from compliance with the securities lending reporting rule (Rule 10c-1a) with
Open Now: Survey on Shareholder Proposals
The John L. Weinberg Center for Corporate Governance, in coalition with several major industry organizations, seeks to gather practical insights from companies, investors, and related professionals about the scope and effectiveness of the current federal shareholder proposal rule (Rule 14a-8) through a new survey.
Recent remarks from the Chairman of the U.S. Securities and Exchange Commission
Risk Transfer Market Receives CPO Registration Relief from CFTC
On November 21, 2025, the Structured Finance Association, on behalf of the risk transfer market, received no-action relief on the issue of registration as a commodity pool operator (“CPO”) from the staff of the Division of Market Participants of the Commodity Futures Trading Commission (“CFTC”). This long-awaited relief provides greater certainty that participants in certain
SEC No-Action Relief Allows a Registered Representative-Owned Personal Services Entity to Receive Transaction-Based Compensation without Broker-Dealer Registration
On November 17, 2025, the staff of the Division of Trading and Markets (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) issued no-action relief permitting a registered representative-owned personal services entity (“PSE”) to receive transaction-based compensation (“TBC”) without registering as a broker-dealer (“BD”) pursuant to Section 15(b) of the Securities Exchange Act of
SEC Division of Examinations Announces 2026 Exam Priorities
Under new SEC leadership, the Division’s 2026 Examination Priorities reflect a modified approach, following a reevaluation of the Division’s risk-based priorities, and a renewed focus on several traditional risk areas (including Regulation Best Interest, adherence to fiduciary standards of conduct, complex products and the Broker-Dealer Financial Responsibility Rules) as well as continued attention to emerging
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
SEC Signals Incoming Relief For De Minimis Security-Based Swap Dealers
On October 29, 2025, Paul Atkins, Chairman of the Securities and Exchange Commission (“SEC”), signaled that he will ask SEC staff to evaluate relief for certain firms who engage in a de minimis level of security-based swap (“SBS”) dealing. While the relief will not be issued as long as the government shutdown persists, his statement