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Crypto Staking: SEC Staff Clarifies Non-Security Status for Certain Protocol Activities

A May 29, 2025, U.S. Securities and Exchange Commission ("SEC") Division of Corporation Finance statement explains that "Covered Crypto Assets"—crypto tokens without any inherent rights to passive income, business enterprise...more

Regulating Digital Assets: New Market Structure Bill Builds on FIT21 Framework

The House Committees on Financial Services and Agriculture have unveiled a discussion draft for a new comprehensive U.S. crypto market structure bill, aiming to establish clear regulatory boundaries between the U.S....more

SEC Division of Corporation Finance: Certain U.S. Dollar-Backed Stablecoins Are Not Securities

As the Trump administration and Congress seek to establish clear digital asset regulation, uncertainty remains on whether federal agencies consider stablecoins to be "securities" under federal law....more

Unanimous Third Circuit Spurs Opportunity, Orders SEC to Justify Crypto Rulemaking Refusal

The ruling that the SEC acted arbitrarily in denying Coinbase's crypto rulemaking petition, issued in the waning days of the Gensler-era SEC, invites swift action under an Atkins-led SEC....more

Who Needs Customers, Anyway? New SEC Rules Turn Traders Into Dealers

The Securities and Exchange Commission (the "SEC" or "Commission") has adopted new rules that further define the phrase "part of a regular business" for purposes of determining whether a person is a "dealer" or "government...more

SEC Reopens Comment Period for Rule Proposing New Disclosures for Security-Based Swaps

The Situation: The Securities and Exchange Commission ("SEC") has reopened the comment period for its proposed rule requiring public disclosure of security-based swap ("SBS") positions that exceed certain thresholds....more

Ripple and Terraform Labs: Two New York District Courts Address the Status of Certain Crypto Assets as Securities

In Short - The Situation: Recently, two judges in Southern District of New York were required to apply the Howey test in separate cases to decide whether sales of certain crypto assets were investment contracts, and thus...more

New Law Exempts M&A Brokers from SEC Registration

In Short - The Situation: Congress recently amended the Securities Exchange Act of 1934 (the "Exchange Act") to exempt certain "M&A brokers" from registration as broker-dealers with the U.S. Securities and Exchange...more

SEC Proposes Rules to Clarify Dealer-Trader Distinction

The SEC's Proposal - On March 28, 2022, the SEC released a rulemaking proposal (the "Proposal") for new rules to clarify the meaning of certain terms in the statutory definitions of "dealer" and "government securities...more

SEC Proposes to Broadly Expand the Definition of an "Exchange" and Amend Regulation ATS

The SEC's Proposal - On January 26, 2022, the SEC released a rulemaking proposal that, among other things, would expand the definition of "exchange" under Rule 3b-16 of the Exchange Act. ...more

SEC Proposes Three New Rules for Securities-Based Swaps

The SEC is considering new rules that would require public position reporting and other requirements for security-based swaps. On December 15, 2021, the SEC proposed three rules under the Securities Exchange Act to...more

SEC Expands Accredited Investor and Qualified Institutional Buyer Categories

The Situation: The term "accredited investor" under the Securities Act of 1933 ("Securities Act") is used to establish the eligibility of investors to participate in offerings conducted under the most frequently used private...more

The Holding Foreign Companies Accountable Act and Related Nasdaq Proposed Rule Changes

Recent measures from U.S. lawmakers and Nasdaq to impose additional requirements on U.S.-listed China-based companies could have wider implications. On May 20, 2020, the U.S. Senate unanimously passed the Holding Foreign...more

Temporary Exemption From Broker Registration for Municipal Advisors

The U.S. Securities and Exchange Commission ("SEC") has granted a temporary exemption from broker registration for certain activities by municipal advisors. On June 16, 2020, the SEC issued a temporary conditional...more

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