Steffen Hemmerich

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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…

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…

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…

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…

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…

On February 21, 2025, Commissioner Hester Peirce released a statement inviting input from interested parties on the regulation of crypto assets.  Commissioner Peirce stated that greater crypto clarity requires the public’s input, and the Crypto Task force therefore welcomes “input from anyone in the public with an interest in these topics, and a wide range…

The Financial Industry Regulatory Authority, Inc. (“FINRA”) published its 2025 Annual Regulatory Oversight Report (the “Report”), which builds on the structure and content of FINRA’s prior reports for 2021-2024. This year, the Report adds new topics relating to the third-party risk landscape, registered index-linked annuities and extended hours trading. The Report also includes new content…

On February 19, 2025, the Securities and Exchange Commission (the “Commission” or “SEC”) dropped its appeal of a ruling by the U.S. District Court for the Northern District of Texas (“District Court”) on November 6, 2024 that struck down the Commission’s “Dealer Rule.”

The Dealer Rule, adopted by the SEC on February 6, 2024, further…

On February 5, 2025, Robert Cook, President and Chief Executive Officer of the Financial Industry Regulatory Industry, Inc. (FINRA), announced that FINRA will not set an effective date for its recent amendments (the “Amendments”) to Trade Reporting and Compliance Engine (TRACE) reporting rules to reduce the current 15-minute timeframe to one minute for reporting transactions…

On December 31, 2024, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 24-18 (“RN 24-18”) to provide updated guidance to members regarding Rules 15c3-1, 15c3-3 and 17a-5 under the Securities Exchange Act of 1934 (“SEA”), Rule 204 under Regulation SHO, FINRA Rules 4210, 4230(b), 4521 and 4524, and Regulation T of the Federal…