SEC Commissioner Speaks Out Against Announcement on No-Action Requests

By Caroline A. Crenshaw November 18, 2025 by Caroline A. Crenshaw

By Announcement today [November 17], the Division of Corporation Finance has apparently determined that, as a matter of “resource and timing considerations,” it will not respond to no-action requests for relief under Rule 14a-8. But, this Announcement is more of …

SEC Commissioner Dissents from Staff Statement on Protocol Staking Activities

By Caroline A. Crenshaw May 30, 2025 by Caroline A. Crenshaw

Channeling the old adage of “fake it ‘till you make it,” today’s statement from the Division of Corporation Finance declares that “protocol staking” – locking up crypto tokens in a blockchain protocol to earn rewards – does not involve an …

SEC Commissioner Criticizes End to Defense of Climate-Related Disclosure Rule

By Caroline A. Crenshaw March 28, 2025 by Caroline A. Crenshaw

Today [March 27], the SEC purports to walk away from the Climate-Related Disclosures Rule.[1] In building the rule, we journeyed up a mountain. The Commission spent at least four years taking input – we issued requests for information, made …

SEC Commissioner Speaks on Finding Balance at the SEC

By Caroline A. Crenshaw March 26, 2025 by Caroline A. Crenshaw

[1] Good morning and thank you for having me. Before I begin, I would like to thank ICI for the invitation to speak here today.[2] I am coming to speak before you during a time of change, both at …

SEC Commissioner Urges Reform of Regulation D and Private Markets

By Caroline A. Crenshaw February 2, 2023 by Caroline A. Crenshaw

Thank you Thomas [Kim] for that lovely introduction and I’m very pleased to be here at the Securities Regulation Institute giving the Alan B. Levenson Keynote Address. Director Levenson was the consummate public servant who left an enduring mark on

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SEC Commissioner Speaks on IPOs and the Rise of SPACs

By Caroline A. Crenshaw April 29, 2022 by Caroline A. Crenshaw

Thank you Hal [Scott] for that kind introduction and for inviting me to speak today. I am honored to precede such an esteemed panel of practitioners and academics. As always, I must give my standard disclaimer that my remarks are

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SEC Commissioner Crenshaw Speaks on Private Fund Advisers Proposal

By Caroline A. Crenshaw February 11, 2022 by Caroline A. Crenshaw

Investment advisers are their clients’ fiduciaries. This means that investment advisers are legally obligated to serve their client’s best interest.[1] This standard of conduct is not an aspirational goal. It must be meaningful and offer the real protections investors

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SEC Commissioner Crenshaw on Universal Proxy Rules

By Caroline A. Crenshaw November 19, 2021 by Caroline A. Crenshaw

Congratulations to the rulemaking team from the Division of Corporation Finance, as well as the staff within the Division of Economic and Risk Analysis and the Office of the General Counsel. This rulemaking has been several years in the making,

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SEC Commissioner Speaks on ESG Risks and Company Accounting Controls

By Caroline A. Crenshaw November 17, 2021 by Caroline A. Crenshaw

Thank you for the kind introduction Kevin [Gould]. It’s a pleasure to be here today at the annual PepsiCo-PwC CPE conference, which I understand is a tradition going back 18 years now. I appreciate the opportunity to speak, and I

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SEC Commissioner Crenshaw Speaks at Small Business Forum

By Caroline A. Crenshaw May 28, 2021 by Caroline A. Crenshaw

Good afternoon! Thank you Martha [Miller] for the warm introduction. It is wonderful to be here. I have truly enjoyed hearing from all of the panelists over the last several days. And I am particularly interested in today’s discussion focused

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Mind the (Data) Gaps: SEC Commissioner Speaks at Conference on Financial Market Regulation

By Caroline A. Crenshaw May 17, 2021 by Caroline A. Crenshaw

Before I begin my remarks, I need to mention that the views that I express today are my own and do not necessarily reflect the views of the Commission or its staff.

To start, I want to note that I

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SEC Commissioner Crenshaw on Shareholder Proposals under Exchange Act Rule 14a-8

By Caroline A. Crenshaw September 24, 2020 by Caroline A. Crenshaw

Today [September 23] the majority of the Commission is approving amendments to the procedures governing shareholder proposals. The amendments are described as a “modernization,”[1] designed to reduce costs for corporations. Even if I agreed that was necessary, I cannot

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The CLS Blue Sky Blog

Columbia Law School's Blog on Corporations and the Capital Markets

Caroline A. Crenshaw