On January 23, 2026, the Securities and Exchange Commission’s Division of Corporation Finance revised a number of Compliance and Disclosure Interpretations (“CDIs”) and issued several new CDIs. The revised CDIs span different topics, from registered exchange offers to proxy solicitations. Overall, the CDIs reflect the current Commission’s focus on addressing regulatory requirements that may impose
Securities Regulation
A Sign of Things to Come on Regulation S-K?
On January 26, 2026, Securities and Exchange Commission Commissioner Mark T. Uyeda delivered remarks at the 53rd annual Securities Regulation Institute. The Commissioner focused his comments on efforts to improve capital formation by, in part, reducing regulatory compliance burdens in those instances in which existing requirements do not provide benefits for investors or the…
SEC Division of Trading and Markets Issues FAQs on Crypto Asset Activities Focusing on Trading and Settlement Issues
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…
House Passes Bipartisan Capital Formation Package: The INVEST Act
Today, the US House of Representatives passed a bipartisan capital formation bill, H.R. 3383 or the Incentivizing New Ventures and Economic Strength Through Capital Formation (“INVEST”) Act of 2025, 302 to 123. Announced by the US House Committee on Financial Services (the “Financial Services Committee”) on December 2, 2025, the INVEST Act includes more than…
SEC Division of Examinations Announces 2026 Exam Priorities
Under new SEC leadership, the Division’s 2026 Examination Priorities reflect a modified approach, following a reevaluation of the Division’s risk-based priorities, and a renewed focus on several traditional risk areas (including Regulation Best Interest, adherence to fiduciary standards of conduct, complex products and the Broker-Dealer Financial Responsibility Rules) as well as continued attention to emerging …
SEC Commissioner Uyeda Provides Update on Implementation of U.S. Treasury Clearing Rules
At the recent 2025 U.S. Treasury Market Conference, Securities and Exchange Commission (“SEC”) Commissioner Mark T. Uyeda provided an update on the implementation of the Treasury Clearing Rules. In his remarks, Commissioner Uyeda said the SEC is focused on resolving regulatory ambiguities and addressing unforeseen issues associated with the implementation of the rules. He noted …
NASAA Amends REIT Guidelines: What Sponsors, Intermediaries, and Investors Need to Know
On September 7, 2025, the North American Securities Administrators Association (NASAA) approved amendments to its Statement of Policy Regarding Real Estate Investment Trusts (the “REIT Guidelines”), which were last amended in 2007. The proposed amendments were last put forth for public comment by NASAA on March 25, 2025.
The REIT Guidelines contain requirements for non-traded…
SEC Provides Updates on Implementation of Treasury Clearing Rules
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…
Division of Corporation Finance Issues No Action Letter to DoubleZero Foundation
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…
Statement by SEC Chairman on the Simultaneous Consideration of Settlement Offers and Related Waiver Requests
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…

