News & Analysis as of

Securities Exchange Act of 1934

Cadwalader, Wickersham & Taft LLP

D.C. Circuit Gives Proxy Advisory Firms a Pass

Appellate Court Holds That Firms’ Voting Recommendations Are Not “Solicitations” Under Section 14(a) of the Securities Exchange Act of 1934- On July 1, 2025, the U.S. Court of Appeals for the D.C. Circuit issued an...more

Mayer Brown Free Writings + Perspectives

Fifth Circuit Remands SEC Securities Lending and Short Sale Rules for Further Economic Analysis

On August 25, 2025, the United States Court of Appeals for the Fifth Circuit issued an opinion in National Association of Private Fund Managers v. SEC addressing Securities and Exchange Commission (SEC or the “Commission”)...more

Sheppard Mullin Richter & Hampton LLP

Ninth Circuit Clarifies SEC Disgorgement Standard, Aligning with the First and Fifth Circuits and Disagreeing with the Second...

In SEC v. Sripetch, No. 24-3830, 2025 WL 2525848 (9th Cir. Sept. 3, 2025), the United States Court of Appeals for the Ninth Circuit affirmed a $2.25 million disgorgement award obtained by the United States Securities and...more

Mayer Brown Free Writings + Perspectives

SEC Grants No-Action Relief from Rule 17a-4 for Reliance on Central Registration Depository System to Maintain Electronically...

On September 5, 2025, the Staff of the Division of Trading and Markets of the U.S. Securities and Exchange Commission (“SEC”) granted no-action relief that allows members of the Financial Industry Regulatory Authority, Inc....more

Freiberger Haber LLP

Enforcement News: Affinity Fraud and Ponzi Schemes in the News Again

Freiberger Haber LLP on

Ponzi schemes and affinity fraud frequently overlap because both exploit trust and social interactions to operate effectively. A Ponzi scheme relies on a continuous stream of new investors to pay returns to earlier...more

Jackson Walker

New Texas Law Applicable to “Nationally Listed Corporations” Sets Forth Heightened Requirements for Shareholder Proposals

Jackson Walker on

Texas Senate Bill 1057, which became effective September 1, 2025, adds new Section 21.373 to the Texas Business Organizations Code (“TBOC”). This new Section of the TBOC creates a framework that governs when and how...more

Sheppard Mullin Richter & Hampton LLP

Ninth Circuit Affirms Dismissal of Securities Fraud Suit: Marketing Slogan Alone Not Actionable Under Section 10(b) and Rule 10b-5

In Sneed v. Talphera, Inc., 2025 WL 2406424 (9th Cir. Aug. 20, 2025), the United States Court of Appeals for the Ninth Circuit affirmed the dismissal of a securities fraud suit against Talphera, Inc. (formerly AcelRx...more

Fenwick & West LLP

Securities Law Update - September 2025

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Welcome to the latest edition of Fenwick’s Securities Law Update. This issue contains updates and important reminders on...more

Mayer Brown Free Writings + Perspectives

SEC Releases Spring 2025 Rulemaking Agenda

On September 4, 2025, the Securities and Exchange Commission’s spring 2025 rulemaking agenda (the “Agenda”) was made publicly available (see here).  Chairman Paul Atkins previewed the Agenda, which widely diverges from the...more

Pierce Atwood LLP

Why Confidential Witness Allegations Fail the Tellabs Test in the District of Massachusetts

Pierce Atwood LLP on

While securities class action filings are on the rise within the First Circuit, the District of Massachusetts continues to apply a high degree of scrutiny to securities fraud allegations, including particularized facts...more

McDermott Will & Schulte

SEC filers must enroll in EDGAR Next by September 15

US Securities and Exchange Commission (SEC) filers have until September 15, 2025, to enroll in Electronic Data Gathering, Analysis, and Retrieval (EDGAR) Next. Any filers not enrolled before the deadline will lose the ability...more

Cooley LLP

What the 2025 No-Action Letter Landscape Tells Us About Preparing for 2026

Cooley LLP on

The 2025 proxy season marked a turning point in the Securities and Exchange Commission’s (SEC) administration of shareholder proposals. Over the course of the season, the staff of the Division of Corporation Finance (staff)...more

Orrick, Herrington & Sutcliffe LLP

SEC Short Interest and Securities Lending Reporting Rules Remanded

On August 25, the United States Court of Appeals for the Fifth Circuit remanded two rules adopted by the Gensler-era SEC: the Securities Lending Reporting Rule and the Short Interest Reporting Rules (the Rules). While the...more

Woodruff Sawyer

Lesser-Known Securities Law Theories and D&O Risk

Woodruff Sawyer on

Most federal private securities litigation is brought under Section 10(b) of the Exchange Act and Section 11 of the Securities Act. These two provisions are responsible for most of the big-ticket securities class actions that...more

A&O Shearman

Sixth Circuit Vacates Class Certification In Securities Fraud Lawsuit Against Electric Services Company

A&O Shearman on

On August 13, 2025, the United States Court of Appeals for the Sixth Circuit vacated a district court order granting class certification in a putative securities class action against an electric services company (the...more

A&O Shearman

Ninth Circuit Affirms Dismissal of Putative Class Action Against Pharmaceutical Company for Failure to Adequately Allege Falsity...

A&O Shearman on

On August 20, 2025, the United States Court of Appeals for the Ninth Circuit affirmed the dismissal of a putative class action asserting claims under the Securities Exchange Act of 1934 against a pharmaceutical company and...more

A&O Shearman

Third Circuit Reinstates Class Action Against Reinsurance Company, With Instructions To Allow Additional Discovery

A&O Shearman on

On August 20, 2025, the United States Court of Appeals for the Third Circuit reinstated a class action asserting claims under the Securities Exchange Act of 1934 against a reinsurance company and certain of its executives. In...more

Wilson Sonsini Goodrich & Rosati

SEC Announces Decrease in Registration Fee Rates Effective October 1, 2025

On August 25, 2025, the U.S. Securities and Exchange Commission (SEC) announced a decrease in the fees that public companies and other issuers will be required to pay to register their securities, from $153.10 per million...more

Cooley LLP

Flowchart: Guide to the 10-K Clawback Checkboxes

Cooley LLP on

We have published a new resource – the “Guide to the 10-K Clawback Checkboxes” – to help guide you through the statutory and regulatory requirements for the Form 10-K clawback checkboxes....more

K&L Gates LLP

United States: Going for Two! SEC Approves Multi-Crypto Asset ETP

K&L Gates LLP on

On 29 July 2025, the US Securities and Exchange Commission (SEC) approved a proposed rule change to list and trade shares of a multi-crypto asset exchange-traded product (ETP), under NYSE Arca Rule 8.201-E. This marks the...more

Latham & Watkins LLP

SEC Staff Clarifies That Liquid Staking Activities Do Not Implicate US Federal Securities Laws

Latham & Watkins LLP on

The Staff provides the market with additional crypto clarity, holding that liquid staking does not qualify as a security under the Howey test....more

Patterson Belknap Webb & Tyler LLP

AI- and Cryptocurrency-Related Securities Class Action Filings in 2025 H1

Cornerstone Research recently published its 2025 midyear assessment of securities class action filings. Compared to the second half of 2024, securities class action filings in the first half of 2025 decreased slightly from...more

Freiberger Haber LLP

Enforcement News: SEC Charges Wisconsin Resident and The LLCs That He Owns and Controls with Perpetrating a Real Estate Affinity...

Freiberger Haber LLP on

On August 1, 2025, the Securities and Exchange Commission (“SEC”) announced (here) that it charged a Wisconsin resident and three limited liability companies that he owns and controls – Investors Capital LLC, Global Investors...more

A&O Shearman

SDNY Allows Control Person Claims To Proceed Against Food & Beverage Executive

A&O Shearman on

On July 28, 2025, Judge Jessica G. L. Clarke of the United States District Court for the Southern District of New York denied a motion for judgment on the pleadings to dismiss a claim under Section 20(a) of the Securities...more

A&O Shearman

District Of New Jersey Dismisses Putative Securities Class Action Against Pharmaceutical Company

A&O Shearman on

On July 30, 2025, Judge Brian R. Martinotti of the United States District Court of the District of New Jersey granted a motion to dismiss a putative securities fraud class action against a drug manufacturing company (the...more

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