On July 1, 2025, the staff of the Division of Corporation Finance at the U.S. Securities and Exchange Commission (the “SEC”) issued another in a series of statements regarding crypto assets. This particular statement, titled “Crypto Asset Exchange-Traded Products,” (the “Statement”) details how certain disclosure requirements under the federal securities laws apply to offerings and
Disclosure Requirements
SEC Office of the Investor Advocate Report
Pursuant to the Securities Exchange Act, the Investor Advocate is required to file two reports annually with the Committee on Banking, Housing and Urban Affairs of the Senate and the Committee on Financial Services of the House of Representatives, which include the mid-year Report on Objectives for the forthcoming fiscal year and end of year…
Congress Introduces Bill to Exempt Fixed-Income Securities from Rule 15c2-11: Inside the “Protecting Private Job Creators Act” (H.R. 3959)
On June 12, 2025, Representative Troy Downing (R-MT) introduced H.R. 3959, the “Protecting Private Job Creators Act.” The bipartisan bill, co-sponsored by Representative Cleo Fields (D-LA), would categorically exempt quotations of all fixed-income securities from the disclosure and information-review obligations of Rule 15c2‑11 under the Securities Exchange Act of 1934, as amended.
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…Out With a Whimper: BCBS Publishes Climate Disclosure Framework
On June 13, the Basel Committee on Banking Supervision (“BCBS”) published its framework for the disclosure of climate-related financial risks. The framework is entirely voluntary and has several notable changes from the 2023 proposal. In this brief Legal Update, we highlight those changes and discuss why the climate disclosure framework will have at best a…
SIFMA and Other Industry Groups Petition SEC for Rescission of Cybersecurity Disclosure Requirement
In late May 2025, the Securities Industry and Financial Markets Association (SIFMA), together with the American Bankers Association, Bank Policy Institute, Independent Community Bankers of America, and Institute of International Bankers submitted a petition to the Securities and Exchange Commission (SEC) requesting rulemaking to amend its Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure rule…
Rethinking Disclosure: Reimagining Executive Compensation Rules
On June 26, 2025, the Securities and Exchange Commission (“SEC”) will host a roundtable to explore potential changes to executive compensation disclosure requirements. This event, highlighted in the SEC’s official announcement and accompanying statement, will bring together public company representatives, investors and other experts to answer questions and discuss potential changes to such requirements. …
Market Trends 2024/25: Disclosure on the Holding Foreign Companies Accountable Act
This practice note discusses the impact of the Holding Foreign Companies Accountable Act (the HFCAA) on securities of foreign companies listed on U.S. exchanges and over-the-counter markets. It provides background on the HFCAA, enacted on December 18, 2020, which reinforces U.S. regulatory authority over SEC-reporting companies relying on auditors in non-U.S. jurisdictions where local authorities…
Market Trends 2024/25: Disclosure on Political Contributions
This practice note explores the evolving trends and practices surrounding the disclosure of political contributions by public companies, particularly in the context of environmental, social, and governance (ESG) issues. It highlights the increasing calls from legal academics, investors, and activist shareholders for the Securities and Exchange Commission (SEC) to mandate disclosures on corporate political spending.
House Financial Services Committee Urges SEC Withdrawal of 14 Proposed and Final Rules
On March 31, 2025, the U.S. House Financial Services Committee (Committee) penned a letter to acting Securities and Exchange Commission (SEC) Chair Mark Uyeda identifying 14 proposed and final rules that, according to the Committee, should be withdrawn in their entirety. All of the cited rules were proposed or implemented under prior SEC Chair Gary…
1940 Act Developments for Business Development Companies
- Structural considerations when considering the launch of a