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On October 29, 2025, Paul Atkins, Chairman of the Securities and Exchange Commission (“SEC”), signaled that he will ask SEC staff to evaluate relief for certain firms who engage in a de minimis level of security-based swap (“SBS”) dealing. While the relief will not be issued as long as the government shutdown persists, his statement…

On October 7, 2025, U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) Chairman Paul Atkins presented the 25th Annual A.A. Sommer, Jr. Lecture on Corporate, Securities, and Financial Law at Fordham University.  Chairman Atkins’ speech touched upon two topics of particular interest—the Wells process and the simultaneous consideration of settlement offers and related…

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…

On September 30, 2025, the Securities and Exchange Commission (“SEC”) issued a press release, providing updates to market participants on the progress of implementing the rules on central clearing of certain secondary market transactions in U.S. Treasury securities (the “Rules”). As we previously discussed, in February 2025, the SEC extended the compliance dates and…

On September 29, 2025, the Chief Counsel’s Office of the U.S. Securities and Exchange Commission’s (the “Commission”) Division of Corporation Finance issued a no action letter to the DoubleZero Foundation (the “Foundation”).  In the no action letter, the Division agreed that it would not recommend enforcement action against the Foundation in connection with certain Programmatic…

On September 26, 2025, Securities and Exchange Commission (SEC) Chairman Paul Atkins announced that the SEC will reinstate its former practice of allowing a party subject to a pending enforcement action to request the SEC to simultaneously consider an offer of settlement and a request for waivers from automatic disqualifications and other collateral consequences resulting…

On September 22, 2025, the Securities and Exchange Commission’s (the “Commission” or “SEC”) Office of the Advocate for Small Business Capital Formation (“OASB”) published its report summarizing policy recommendations made during the 44th Annual Small Business Forum (the “Forum”).  The Forum brought members of the public and private sectors together to provide feedback relating to…

On September 26, 2025, the Securities and Exchange Commission published a concept release requesting comments on whether to amend the asset-level disclosure requirements for residential mortgage-backed securities (RMBS) in Item 1125 of Regulation AB.  The release solicits comments on whether to revise the definition of “asset-backed security” and/or other definitions in Item 1101 of Regulation AB. …