Sky Blog
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, …
In a new essay, I compare a judicial revolution that is happening with one that is not. Both the change and the status quo are being managed by the current Supreme Court. , When it comes to administrative law, the …
In order to keep the compliance folks here at the SEC happy, I must first note that the views I express here today are my own and do not necessarily reflect those of the full Commission or of my fellow …
Last year, an asset manager with offices in New York, Texas, and Vermont was publicly censured by the Securities and Exchange Commission and ordered to pay a substantial fine. Its offense? The asset manager hired an individual who had previously …
We write in opposition to the hasty and opaque efforts underway to abolish the Public Company Accounting Oversight Board (PCAOB), the nonprofit organization that oversees audits of public companies and SEC-registered brokers and dealers in the United States, currently overseen …
The topic of this afternoon’s discussion is timely as securities are increasingly migrating from traditional (or “off-chain”) databases to blockchain-based (or “on-chain”) ledger systems.[1]
President Trump signed on February 10 an executive order (the “Executive Order”)[1] directing the U.S. Attorney General over the next 180 days to (i) review the guidelines and policies governing investigations and enforcement actions under the Foreign Corrupt Practices …
On April 25, 2025, the SEC Staff issued two new Compliance and Disclosure Interpretations (C+DIs) with respect to Rule 10b5-1. Under the first (Qu. 120.32), the Staff advised that purchases and sales of issuer securities pursuant to a …
Welcome to the penultimate day of the SEC’s 31st International Institute for Securities Market Growth and Development. Before I begin, as I am sure you anticipate based on what you have heard from many SEC speakers this week, my …
Good morning. Today is the sixth-year anniversary of the first-ever meeting of the Small Business Capital Formation Advisory Committee.[1] Since that initial meeting, I have followed the discussions and recommendations by this Committee from outside the agency. Now it …
Corporations play an increasingly active role in lobbying, with a growing focus on influencing government rulemaking. According to the Center for Responsive Politics, corporate lobbying expenditures at the federal level reached a record $3.7 billion in 2024, accounting for 86.3 …
Congress seems on its way to passing the first piece of federal crypto-regulation, the Guiding and Establishing National Innovation for U.S. Stablecoins – or GENIUS – Act. The law would create a comprehensive regulatory framework for payment stablecoins, which are …
In 2024, the Securities and Exchange Commission (SEC) issued Wells notices to at least 13 crypto companies – several of which were decentralized finance (DeFi) platforms – including Uniswap Labs (Uniswap), the second largest decentralized exchange (DEX) by trading volume
On November 25, 2024, plaintiffs Sjunde AP-Fonden and The Cleveland Bakers And Teamsters Pension Fund (together “Plaintiffs”) moved Judge Jesse Furman of the U.S. District Court for the Southern District of New York (the “Court”) for preliminary approval of a …
On April 4, 2025, a federal district court in Colorado dismissed a Section 11 claim arising out of a direct listing and concluded that recent Supreme Court precedent “likely forecloses Section 11 liability in the direct listing context” altogether. The …
The SEC’s Division of Corporation Finance has announced improvements to its policies for draft registration statements that will be welcomed by both companies and underwriters.
Following recent statements by Acting SEC Chair Mark Uyeda calling for a return to the …
Over recent decades, the massive globalization of finance has led many observers to expect widespread harmonization of nations’ financial regulations. Yet, while there has been a remarkable degree of harmonization in some areas, at least at the regional level, considerable …