Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more
7/1/2025
/ Banking Regulators ,
Banking Sector ,
Basel III ,
Capital Markets ,
Capital Requirements ,
Comment Period ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
OCC ,
Proposed Rules ,
Regulatory Reform
On June 23, 2025, the House of Representatives (the “House”) passed seven bills relating to capital formation. As discussed in a previous post, these bills were reported to the House by the House Committee on Financial...more
The Securities and Exchange Commission (SEC) formally withdrew the following proposed Gensler era rulemakings:
Substantial Implementation, Duplication, and Resubmission of Shareholder Proposals Under Exchange Act Rule...more
On May 5, 2025, the Republican committee chairs in the US House of Representatives with jurisdiction over digital asset legislation released a digital asset market structure discussion draft bill (the “Discussion Draft”). The...more
5/28/2025
/ Asset Management ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Financial Regulatory Reform ,
New Legislation ,
Proposed Legislation ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Stablecoins
At yesterday's Practising Law Institute’s SEC Speaks program, Securities and Exchange Commission (“SEC”) Chair Paul Atkins shared his views on a wide range of topics. Chair Atkins touched on innovation at the SEC, FinHub and...more
The Securities and Exchange Commission’s (SEC) Small Business Capital Formation Advisory Committee (the “Committee”) will meet on May 6, 2025 to consider the market impact and challenges associated with Regulation A....more
Acting SEC Chair Uyeda spoke at the Institute of International Bankers’ (IIB) Annual Washington DC Conference on March 11, 2025, about the U.S. Treasury markets.
Acting Chair Uyeda discussed the regulation of exchanges....more
On February 28, 2025, House Financial Services Committee Chairman French Hill (R-AR), Senate Banking Committee Chairman Tim Scott (R-SC), and Senator Tom Cotton (R-AR) sent a letter (the “Letter”) to Securities and Exchange...more
The Securities and Exchange Commission (SEC) announced that Mark T. Uyeda has been appointed Acting Chair. The Acting Chair has served as an SEC Commissioner since June 2022 and brings extensive experience to the role,...more
On May 22, 2024, the US House of Representatives passed H.R. 4763, the Financial Innovation and Technology for the 21st Century Act (FIT21), which would amend existing securities and commodity regulatory statutes to...more
6/4/2024
/ CFTC ,
Cryptocurrency ,
Digital Assets ,
Financial Regulatory Reform ,
Investment ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Authority ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stablecoins
On March 8, 2024, the House of Representatives passed the Expanding Access to Capital Act, H.R. 2799, which we had previously posted on the blog.
...more
3/11/2024
/ 403(b) Plans ,
Angel Investors ,
Capital Formation ,
Collective Investment Schemes ,
Financial Regulatory Reform ,
General Solicitation ,
Investment Opportunities ,
Proposed Amendments ,
Regulatory Agenda ,
Retirement Plan ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and...more
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and...more
In recent years, there has been a proliferation of exempt offering alternatives. In advising clients regarding which exempt offering alternative may best meet their objectives, we often suggest that they consider, among other...more
Recently, the US Securities and Exchange Commission (“SEC”) adopted amendments to the definition of accredited investor (“AI”) and amendments to the definition of Qualified Institutional Buyer (“QIB”). Our updated investor...more
FINRA filed with the Securities and Exchange Commission (SEC) proposed amendments to the private placement filer form that members complete in connection with private placement filings made pursuant to either Rule 5122 or...more
In its 2019 Concept Release on Harmonization of Securities Offerings,1 the US Securities and Exchange Commission (SEC) included a section requesting comment regarding resale exemptions, including Rule 144. While the SEC...more
The implications of the 2020 election for structured finance are coming into focus. Informed by our discussions in Washington, we can anticipate the likely direction of federal policy over the next two years that will impact...more
12/9/2020
/ Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Financial Regulatory Reform ,
GSE ,
Infectious Diseases ,
Inter-Bank Offered Rates (IBORs) ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Structured Finance ,
UK Brexit ,
Volcker Rule
The Securities and Exchange Commission continues to move forward with its rulemaking agenda. Yesterday, the SEC announced that it voted to adopt amendments to the MD&A disclosure requirements. These had been proposed at the...more
11/20/2020
/ Corporate Governance ,
Disclosure Requirements ,
Financial Regulatory Reform ,
Financial Statements ,
MD&A Statements ,
Publicly-Traded Companies ,
Regulation S-K ,
Regulatory Oversight ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
The Staff of the Division of Corporation Finance of the Securities and Exchange Commission released a new Compliance & Disclosure Interpretation, 139.13, relating to equity lines, and has withdrawn several C&DIs.
...more
On August 26, 2020, the US Securities and Exchange Commission (SEC) adopted amendments to Regulation S-K that are intended to modernize business, legal proceedings and risk factor disclosures. According to the SEC, the...more
At an open meeting held yesterday morning, the Securities and Exchange Commission voted to adopt the previously proposed amendments to Regulation S-K Items 101, 103 and 105. These changes affect the Business section, Risk...more
Today, the Securities and Exchange Commission adopted long-awaited changes to the definition of “accredited investor,” as well as some conforming changes to the definition of “qualified institutional buyer.” ...more
On January 30, 2020, the US Securities and Exchange Commission (SEC) provided guidance (MD&A Guidance) regarding the disclosure of key performance indicators and metrics used in the Management’s Discussion and Analysis of...more
2/5/2020
/ Corporate Governance ,
Deregulation ,
Disclosure Requirements ,
Financial Regulatory Reform ,
Financial Statements ,
Form 10-K ,
Form 20-F ,
MD&A Statements ,
New Guidance ,
Omissions ,
Performance Standards ,
Publicly-Traded Companies ,
Regulation S-K ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC)
In remarks last week, Securities and Exchange Commission Chair Clayton discussed the SEC’s proposed amendments to streamline and modernize the requirements for Management’s Discussion and Analysis (MD&A) disclosures. The...more
2/4/2020
/ Corporate Governance ,
Disclosure Requirements ,
Financial Regulatory Reform ,
Financial Statements ,
MD&A Statements ,
PCAOB ,
Proposed Amendments ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Oversight ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Regulation