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On December 11, 2025, the staff of the Division of Trading and Markets of the Securities and Exchange Commission issued a no-action letter to The Depository Trust Company (“DTC”) concerning a pilot version (the “Preliminary Base Version”) of a securities tokenization program, referred to as the “DTCC Tokenization Services.” The letter permits DTC to conduct…

The Securities and Exchange Commission’s Office of the Investor Advocate is required by Congress to produce and submit two reports annually to the Committee on Banking, Housing, and Urban Affairs of the Senate and the Committee on Financial Services of the House of Representatives.  This report covers the Office’s Report on Activities for the Fiscal…

On December 17, 2025, the staff of the Division of Trading and Markets (the “Staff”) of the Securities and Exchange Commission (“SEC”) released an update to its May 2025 FAQs relating to crypto asset activities and distributed ledger technology.  The additional FAQs focus on trading and settlement issues, including how alternative trading systems (“ATSs”) and…

On December 15, 2025, Nasdaq submitted a proposed rule change to the Securities and Exchange Commission (the “SEC”) seeking approval to expand significantly its equity trading hours.  If approved, the change would allow trading in Nasdaq-listed equity securities and exchange-traded products for 23 hours per weekday, representing a notable shift in U.S. equity market structure. …

On December 12, 2025, The Nasdaq Stock Market LLC (“Nasdaq”) filed a proposed rule change with the Securities and Exchange Commission (“SEC”) that would expand Nasdaq’s authority to deny initial listing, even when an issuer satisfies all applicable quantitative and corporate governance listing requirements. Nasdaq states that the proposal is intended to support meaningful listing…

On December 8, 2025, the Securities and Exchange Commission (“SEC”) approved proposed rule changes submitted by The Nasdaq Stock Market LLC (“Nasdaq”) that exempt certain over-the-counter (“OTC”)-traded SPACs from the reverse merger rule and minimum average daily trading volume requirements. Citing a recent increase in the number of SPACs that were listed at the time…

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)…

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…

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…