The Staff of the SEC’s Division of Investment Management issued a no-action letter on April 27, 2026 to J.P. Morgan Investment Management, Inc. (“JPMIM”) addressing the application of an existing co-investment exemptive order to certain open-end funds and the operation of the “Required Majority” condition.  JPMIM requested assurance that open-end funds advised or sub-advised by

On April 16, 2026, the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (“SEC”) issued an exemptive order allowing certain qualifying tender offers for equity securities to remain open for a minimum of 10 business days, instead of the 20 business days required under the Securities Exchange Act of 1934 (the

The Securities and Exchange Commission’s next meeting of the Small Business Capital Formation Advisory (“SBCFA”) Committee convenes April 28, 2026, to explore ways to encourage more companies to go public.  The SBCFA Committee will hear from members on the state of the IPO market while considering the existing regulatory framework and how IPO activity and

On April 10, 2026, five trade associations—the American Bankers Association, the Bank Policy Institute, SIFMA, the Independent Community Bankers of America, and the Institute of International Bankers—submitted a joint comment letter to the Securities and Exchange Commission in response to Chair Atkins’ request for comment on Regulation S-K.  The letter urges the SEC to rescind

On April 17, 2026, the Securities and Exchange Commission (SEC) approved with immediate effectiveness the New York Stock Exchange’s (NYSE) proposed rule change (SR-NYSE-2026-17) that allows tokenized securities to be listed and traded on the NYSE.  The NYSE rule would integrate blockchain-based representations of traditional stocks and ETFs into its existing trading infrastructure.  Like Nasdaq’s

On April 16, 2026, the Division of Corporation Finance (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) issued an exemptive order granting relief for certain tender offers from the requirement that such offers remain open for at least 20 business days.  In response, in part, to technological improvements, and consistent with previous relief from this requirement, the

A rulemaking petition filed recently highlights the need to address the communications safe harbors.  The Securities and Exchange Commission has not reviewed the rules and regulations relating to social media under the securities laws since 2000. The last comprehensive review of the rules relating to offering related communications and safe harbors was Securities Offering Reform

On March 27, 2026, the Securities and Exchange Commission (“SEC”) announced its intention to adjust the dollar thresholds used under the Investment Advisers Act of 1940 in determining when a registered investment adviser may charge performance‑based fees.  These fees, which tie adviser compensation to investment gains, are generally prohibited except in respect of “qualified clients”

On March 24, 2026, Securities and Exchange Commission Commissioner Hester Peirce spoke at the Investment Company Institute’s 2026 Investment Management Conference laying out a pragmatic path to modernize the fund regulatory framework.  Her remarks emphasized that many of the industry’s longstanding pain points are well understood and, in some cases, readily fixable.  Among several key

On March 19, 2026, the SEC staff issued a new Compliance and Disclosure Interpretation (Question 116.26) addressing how Form S-3 eligibility may impact an existing at-the-market (ATM) offering.  The interpretation considers a situation where a company establishes an ATM offering while it qualifies under General Instruction I.B.1, which allows companies with at least $75 million