On September 30, 2025, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission granted no-action relief that allows, subject to numerous conditions: (i) investment advisers registered under the Investment Advisers Act of 1940, as amended (the “Advisers Act”); and (ii) investment companies registered under the Investment Company Act of
Steffen Hemmerich
SEC Grants No-Action Relief from Rule 17a-4 for Reliance on Central Registration Depository System to Maintain Electronically Signed Form U4 Filings
By Steffen Hemmerich, Anna T. Pinedo & Stephen Vogt on
On September 5, 2025, the Staff of the Division of Trading and Markets of the U.S. Securities and Exchange Commission granted no-action relief that allows members of the Financial Industry Regulatory Authority, Inc. (“FINRA”) to rely on the Central Registration Depository system (“CRD”) to satisfy their record retention requirements under Rule 17a-4 under the Securities…
SEC Staff Issues Guidance on Rule 15c3-3a and Treasury Clearing
On August 6, 2025, the Staff of the Division of Trading and Markets of the Securities and Exchange Commission (SEC) released an updated set of Frequently Asked Questions (FAQs) addressing the application of Rule 15c3-3a to cleared US Treasury securities. While these responses reflect only staff views and are not an SEC rulemaking, they provide…
Digital (Tokenized) Bonds: What to Know About a Growing Asset Class
By Matthew Bisanz & Steffen Hemmerich on
Webinar | August 11, 2025
1:00 p.m. – 2:00 p.m. EDT
Register here.
Tokenized bonds are one asset class that is quickly emerging from the amorphous pool of digital asset projects. Hosted by PLI, this webinar will provide an overview of the fundamentals of tokenized bonds, how they are structured, and how they have…
SEC Formally Withdraws Various Proposed Rules
By Steffen Hemmerich & Anna T. Pinedo on
- Conflicts of
SEC Division of Trading and Markets Releases FAQs on Crypto Asset Activities and Distributed Ledger Technology; 2019 Joint Staff Statement on Broker-Dealer Custody of Digital Asset Securities Withdrawn
On May 15, 2025, the staff of the Securities and Exchange Commission (“SEC”) Division of Trading and Markets (the “Staff”) published responses to certain frequently asked questions (“FAQs”) relating to crypto asset activities and distributed ledger technology as they relate to broker-dealer financial responsibility and transfer agent activities. Importantly, the Staff’s responses to the FAQs…
SEC Crypto Task Force Holds Roundtable on Tokenization
On May 12, 2025, the Securities and Exchange Commission (“SEC”) held a Crypto Task Force roundtable to explore an appropriate regulatory framework for tokenized securities. In the keynote address, Chair Paul Atkins, stated that a key priority of his tenure will be the development of a rational regulatory framework for crypto asset markets. His focus…
SEC Commissioner Peirce remarks on the Regulation of Tokenized Securities
On May 8, 2025, the Securities and Exchange Commission (“SEC”) held the 31st International Institute for Securities Market Growth and Development. Commissioner Peirce used this opportunity to discuss an approach to regulating the tokenization of traditional securities—in other words, issuing traditional securities through a blockchain or distributed ledger.
The Commissioner noted that other jurisdictions have…
SEC Crypto Task Force Holds Roundtable on Crypto Custody
On March 25, 2025, the Securities and Exchange Commission (“SEC”) held a Crypto Task Force roundtable to explore regulatory considerations surrounding custody of crypto assets through broker-dealers and other financial institutions, such as state chartered limited purpose trust companies. Newly installed SEC Chairman Paul S. Atkins opened the roundtable by stating that he expects “huge…
Lawmakers Ask SEC Acting Chair Uyeda to Review Approach to Consolidated Audit Trail
By Stephen Vogt, Steffen Hemmerich & Anna T. Pinedo on
On February 28, 2025, House Financial Services Committee Chairman French Hill (R-AR), Senate Banking Committee Chairman Tim Scott (R-SC), and Senator Tom Cotton (R-AR) sent a letter (the “Letter”) to Securities and Exchange Commission (the “Commission”) Acting Chair Mark Uyeda requesting that the Commission launch a comprehensive review of all aspects of the Consolidated Audit…