On June 10, 2026, the Commodity Futures Trading Commission (“CFTC” or the “Commission”) published a notice of proposed rulemaking (the “NPRM”) proposing amendments to CFTC Regulation 40.11 and the addition of Appendix F to Part 40, concerning event contracts. The CFTC is proposing to specify the types of event contracts that may be deemed contrary
Securities Regulation
A New Day, A New Plan: SEC Publishes Draft Strategic Plan for FY2026-FY2030
On June 2, 2026, the U.S. Securities and Exchange Commission (the “SEC”) published its Draft Strategic Plan for fiscal years 2026-2030, formally incorporating Chair Paul Atkins’ deregulatory and innovation-focused vision into the agency’s governing framework. The plan is organized around three strategic goals: (1) renewing regulatory policy, (2) reforming enforcement and stakeholder engagement, and (3)…
SEC Proposal: Market Data on BDCs and Closed-End Funds
On May 19, 2026, the SEC released two proposed rule amendments aimed at modernizing the registered offering framework and simplifying ongoing reporting obligations for public companies. The economic analysis accompanying the “Registered Offering Reform” proposal provides a detailed snapshot of the current landscape for business development companies (“BDCs”) and closed-end funds (“CEFs”), including…
Chair Atkins Previews Additional Potential IPO and Communications Rules Changes
Speaking today at the Stanford Rock Center for Corporate Governance, Securities and Exchange Commission (“SEC”) Chair Atkins recapped a number of the key achievements and rulemaking proposals, including the two significant proposals released just last week, about which we blogged (see our first post and second post), all of which are intended to encourage…
Leveling the Shelf: The SEC’s Proposal on Registered Offering Reform
On May 19, 2026, the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”) proposed extensive amendments to the registered offering framework under the Securities Act of 1933, as amended (the “Securities Act”). The SEC’s rulemaking proposal on Registered Offering Reform (the “Proposal”) has the potential to be the most significant offering reform in…
SEC Proposes Rules Simplifying Filer Status Determinations and Increasing Disclosure Accommodations
On May 19, 2026, the U.S. Securities and Exchange Commission (the “SEC”) published two rulemaking proposals, each of which would substantially revise the requirements of the U.S. federal securities laws applicable to public companies. These proposals mark the next step in SEC Chair Paul Atkins’ mission to grow the U.S. capital markets and “make IPOs…
SEC Proposes Rules to Enhance Filer Accommodations and Simplify Filer Status for Reporting Companies
As noted in our earlier post, the Securities and Exchange Commission (“SEC”) released two rulemaking proposals aimed at overhauling how public companies access the capital markets and address their ongoing reporting obligations.
The second rulemaking proposal, “Enhancement of Emerging Growth Company Accommodations and Simplification of Filer Status for Reporting Companies,” would simplify the filer…
SEC Proposes Rules to Reform Registered Offering Framework
Today, the Securities and Exchange Commission (“SEC”) proposed two sets of rule amendments aimed at overhauling how public companies access the capital markets and meet their ongoing reporting obligations. The first rulemaking proposal, “Registered Offering Reform,” seeks to modernize the registered offering framework by, among other things, broadening eligibility for streamlined registration forms and extending…
The Past is Prologue – Availability of SEC Registration for Canadian Covered Bonds
In 2012, the SEC Staff granted no action relief to Royal Bank of Canada to register covered bonds on a Registration Statement on Form F-3. Even though covered bonds are not “asset-backed securities,” that relief was predicated on the covered bond Guarantor complying with certain reporting requirements under Regulation AB. When Regulation AB was amended…
Do Crypto User Interface Providers Need to Register as Broker-Dealers with the SEC? The Staff Offers Its View
The Staff of the Division of Trading and Markets (the “Staff”) of the Securities and Exchange Commission (the “SEC” or the “Commission”) recently issued a statement (the “Statement”) providing its views on the application of the broker-dealer registration requirements under Section 15(a) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), to…

