Sky Blog
The World Resource Institute’s Greenhouse Gas (GHG) Protocol Corporate Accounting and Reporting Standard (the “GHG Protocol”) has been widely adopted as a framework for companies to report Scope 1, 2, and 3 emissions. By allowing companies to apply market-based procurement …
On June 23, 2025, the District Court for the Northern District of California dismissed a Section 11 claim where non-executive employees of the issuer were permitted to sell a portion of their preexisting shares to the public in connection with …
Last month, we circulated Shadow SEC Statement No. 4, which urged caution in legislating major changes in the Public Company Accounting Oversight Board (“PCAOB”) or its funding. The Senate nonetheless took up a bill that would have transferred the PCAOB’s …
Shareholders and investor advocacy groups have long criticized executives for being paid top dollar while achieving subpar returns for shareholders. In response, the Securities and Exchange Commission (SEC) passed the Dodd-Frank Act of 2010, which has two, related provisions that …
Good afternoon. Thank you to Chairman Atkins for convening today’s roundtable and thank you to the moderators and panelists for joining us to discuss this important topic. On a recent trip to Alaska, one of the most striking sights was …
The U.S. investment crowdfunding market is quietly facing a crisis.
A troubling number of startups have raised capital from everyday investors under Regulation Crowdfunding (Reg CF)—and then disappeared, ghosting the crowd by failing to file the annual reports required by …
On June 4, 2025, the U.S. Securities and Exchange Commission (the “Commission” or “SEC”) issued a concept release soliciting public comment on the definition of foreign private issuer (“FPI”), particularly on whether the current definition should be amended in an …
On June 12, the SEC withdrew 14 proposed rules stating that it did not intend to issue final rules with respect to the proposals and that if the SEC decides to pursue future regulatory action in any of these areas, …
In a recent article, we explore the curious case of how regulators in the EU, UK, and United States treat two forms of insider trading — what we call “traditional insider trading” and “shadow trading.” The former, familiar to …
On May 29, 2025, the staff of the SEC’s Division of Corporation Finance (the “Staff”) issued a statement concluding that certain proof-of-stake blockchain “staking” activities do not involve the offer or sale of “securities” within the meaning of the Securities …
The Federal Trade Commission and the DOJ’s Antitrust Division recently announced two settlement agreements, signaling that this Administration is willing to resolve merger competition concerns — in appropriate cases — through negotiated divestiture remedies. These actions herald a return to …
For nearly 40 years, regardless of whether confidential information belonged to a governmental entity or a private-sector business, its misappropriation could be prosecuted as a property crime. Lower federal courts relied on Carpenter v. United States,[1] a well-known …
As regulators and policymakers across the federal government press forward with creating long-sought rules of the road for the cryptoasset industry, several recent developments bear particular significance for the promise of the decentralized internet, or Web3. Among these is the …
Good afternoon. This is an open meeting on June 4, 2025 of the U.S. Securities and Exchange Commission under the Government in the Sunshine Act. Commissioners Caroline Crenshaw and Mark Uyeda are here with me in Washington, D.C., and Commissioner …
For the month when Paul Atkins was sworn in as SEC Chairman, we examine:
Artificial intelligence (AI) tools, particularly large language models, are quickly becoming integral to financial advising. Recent evidence, however, demonstrates that they can act against investors’ interests. In a 2023 experiment,researchers deployed GPT‑4 as an autonomous trading agent and found that …
Chairman Hagerty, Ranking Member Reed, and members of the Subcommittee. Thank you for inviting me to testify today.[1]
I am grateful for the opportunity to discuss the Securities and Exchange Commission, including our important mission on behalf of our
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 …
On May 20, 2025, the New York Court of Appeals affirmed the dismissal of two shareholder derivative actions brought against directors and officers of large European companies in decisions with critical implications for non-U.S. companies’ exposure to fiduciary litigation in …
Chairman Joyce, Ranking Member Hoyer, and members of the Subcommittee. Thank you for inviting me to testify today.[1]
I am grateful for the opportunity to discuss the SEC, including our important mission on behalf of our fellow citizens, investors, …