Cleary Discusses Labor Department’s Proposed Rule on 401(k)s and Alternative Assets

On March 30, 2026, the U.S. Department of Labor (the DOL) published its heavily anticipated proposed rule entitled “Fiduciary Duties in Selecting Designated Investment Alternatives” (the Proposed Rule).[1] Over the years, sponsors of private funds and other investment vehicles …

Sullivan & Cromwell Discusses Warnings to Bank CEOs About Cybersecurity Risks of Anthropic’s New AI Model

On April 7, 2026, Treasury Secretary Scott Bessent and Federal Reserve Chair Jerome Powell convened an urgent, closed-door meeting with the CEOs of some of the nation’s largest banks to discuss the cybersecurity risks posed by Anthropic’s newly announced AI …

Sullivan & Cromwell Discusses Proposed FSOC Changes to Nonbank SIFI Designation Guidance

On March 25, 2026, the Financial Stability Oversight Council (the “Council”) unanimously voted to propose amendments to its interpretive guidance (the “Proposed Interpretive Guidance”) regarding the designation of nonbank financial companies as “systemically important financial institutions” (“SIFIs”) for supervision by …

Cleary Discusses Prediction Market Considerations for Public Companies

Prediction markets allow participants to trade contracts on whether or not real-world events will occur. These platforms have grown rapidly, and contracts tied to specific company activity are now actively trading, including contracts on IPOs, mergers and acquisitions, earnings call …

Sidley Discusses CFTC Guidance, Advance Notice of Proposed Rulemaking for Prediction Markets

The U.S. Commodity Futures Trading Commission (CFTC or the Commission), under Chairman Michael Selig’s leadership, has taken an expansive view of its authority over prediction markets, arguing that the agency has exclusive jurisdiction over event contracts traded on designated contract …