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SEC Investor Advocate Report on Objectives

The Securities and Exchange Commission’s Office of the Investor Advocate recently issued its fiscal year 2025 Report on Objectives. The Report is one of two annual reports required to be filed by the Investor Advocate with...more

FINRA Reminds Members of Regulatory Obligations When Using Generative Artificial Intelligence (AI) and Large Language Models

On June 27, 2024, the Financial Industry Regulatory Authority, Inc. (“FINRA”) issued Regulatory Notice 24- 09 (the “Notice”) reminding member firms that FINRA’s rules and the securities laws apply to the use of artificial...more

DFA Era Incentive-Based Compensation Rule

In recent remarks, Securities and Exchange Commission Commissioner Lizarraga called on the SEC to move forward to implement the rulemaking mandate in Section 956 of the Dodd-Frank Act.  The Commissioner was speaking at an...more

Investment Research

During his remarks at a meeting of the International Bar Association’s Asset Management Industry Conference on Global Challenges and Opportunities in Boston, Commissioner Uyeda commented on investment research and the...more

Chair Gensler Testimony Before House Subcommittee

Chair Gensler recently testified before the Subcommittee on Financial Services and General Government in connection with the Securities and Exchange Commission budget request.  In his testimony, the Chair included a number of...more

Commissioner Comments on Tokenization

Commissioner Uyeda spoke at the Securities and Exchange Commission’s 30th Annual Institute for Securities Market Growth and Development. Commissioner Uyeda focused on the need to root out bad actors and promote transparent...more

House Passes Digital Asset Market Structure Legislation: Financial Innovation and Technology for the 21st Century Act (FIT21)

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

SEC Approves Listings of Spot Ether ETFs: Waiting is the Hardest Part

On May 23, 2024, the Staff of the Securities and Exchange Commission’s Division of Trading and Markets (the “SEC”) approved rule changes (so-called “19b-4 forms”) permitting the listing and trading of eight separate...more

SEC’s Upcoming Investor Advisory Committee Meeting: Finfluencers and AI

The Securities and Exchange Commission announced an upcoming meeting of its Investor Advisory Committee, which will be held on June 6, 2024.  The agenda includes a number of interesting topics....more

Avoiding Cybersecurity Incident Overdisclosure:  Helpful Guidance

In a statement yesterday, the Director of the SEC’s Division of Corporation Finance commented on the relatively new Form 8-K Item 1.05 requirement.  Last summer when the SEC adopted the final rules relating to cybersecurity...more

SEC Adopts Amendments to Regulation S-P

On May 15, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) to Regulation S-P under the Securities Exchange Act of 1934 (the “Exchange Act”), which governs the treatment of...more

Emerging Trends in Asset Management

Speaking at the recent conference on Emerging Trends in Asset Management hosted by the SEC’s Division of Investment Management, the Director the Division of Investment Management Natasha Vij Greiner cited a number of...more

Joint Statement on Application of IFRS 19 in SEC Filings

On May 17, 2024, the Director of the Division of Corporation Finance of the Securities and Exchange Commission, Erik Gerding, and the Chief Accountant, Paul Munter, issued a statement regarding International Financial...more

The SEC and Capital Formation

Not long ago, the SEC hosted the Annual Small Business Forum.  The Forum provides an opportunity to consider a broad array of issues affecting private companies as well as smaller public companies seeking to raise capital and...more

Upcoming SEC Small Business Advisory Committee

The Securities and Exchange Commission announced an upcoming meeting of its Small Business Capital Formation Advisory Committee on May 6, 2024.  The meeting will include a discussion of Regulation Crowdfunding (Reg CF) and...more

The 3 E’s for Proactive Compliance Against AI-Washing

On April 15, 2024, Securities and Exchange Commission Division of Enforcement Director Gurbir Grewal delivered remarks during a Program on Corporate Compliance and Enforcement Spring Conference 2024.  He addressed artificial...more

SEC Stays Climate-Related Disclosure Rules

The SEC paused implementation of the climate-related disclosure rules in the face of significant legal challenges.  The rules would impose substantial disclosure mandates on companies, including concerning the costs of...more

US Appeals Court Temporarily Halts SEC's Climate Change Disclosure Rules

On March 15, 2024, the US Court of Appeals for the Fifth Circuit granted an administrative stay of the climate-related disclosure rules recently adopted by the US Securities and Exchange Commission (the “SEC”). The SEC rules...more

Broker-Dealer Settles FINRA Charges for Failures Relating to Use of Social Media Influencer Program

On March 18, 2024, FINRA announced that it has fined a broker-dealer $850,000 in connection with the firm’s program to pay individuals with followings on social media sites (i.e., “influencers”) to promote the firm in social...more

The SEC Brings Another Enforcement Action On Related Party Transaction Disclosures

On March 7, 2024, the Securities and Exchange Commission (the “SEC”) announced that Skechers U.S.A. Inc. (“Skechers”) agreed to a cease-and-desist order for failing to disclose payments for the benefit of its executives and...more

SEC Adopts Climate Change Disclosure Rules Applicable To Public Companies And Offerings

The Securities and Exchange Commission (the “SEC”) has adopted new rules that require public companies to disclose substantial information about the material impacts of climate-related risks on their business, financial...more

Climate-Risk Disclosure Rules

The Securities and Exchange Commission adopted (in a 3-2 vote) final rules related to climate-related disclosures.  These rules had first been proposed in March 2022.  In his opening remarks, SEC Chair Gensler noted that the...more

Upcoming Investor Advisory Committee Meeting

The Securities and Exchange Commission’s Investor Advisory Committee will hold a meeting on March 7, 2024, during which it will discuss the SEC’s equity market structure proposals.  The Committee also will consider a...more

ESG and SEC Enforcement

As we anticipate, with some trepidation, this week’s final climate change disclosure rules from the Securities and Exchange Commission, it’s important to remember that those rules will remain only a part of the agency’s ESG...more

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