Sky Blog
Today [December 11] the Financial Stability Oversight Council (FSOC) received a briefing from Treasury staff on potential revisions to the Council’s interpretative guidance regarding nonbank financial company determinations. And I was especially encouraged to see revising the non-bank designation guidance …
Good morning and thank you Aaron [Klein]. It is a pleasure to be here this morning. While this isn’t a “farewell address,” I hope you will indulge me if I take the opportunity to reflect a little bit on what …
In October 2025, Bitcoin experienced its largest single-day crash since the COVID-19 pandemic, a 20% decline that economist Paul Krugman attributed not to economic fundamentals but to threats against Donald Trump’s political standing. 1 Krugman’s diagnosis was stark: Bitcoin had …
Good morning, ladies and gentlemen. Lynn, let me start by thanking you for your generous introduction and for hosting this event at the Exchange. My thanks as well to the market participants here today. And of course, I am grateful …
The rise of Special Purpose Acquisition Companies (SPACs) as an alternative pathway to public markets represents one of the most significant features of entrepreneurial ventures in the last few years. Between 2020 and 2021, SPACs accounted for over 40% of …
On November 12, 2025, SEC Chairman Paul Atkins delivered remarks (the November Remarks) revisiting his announcement of “ Project Crypto,” the Commission-wide initiative launched earlier this year to promote blockchain innovation in U.S. financial markets. Chairman Atkins laid …
If you practice securities litigation, you know the drill: When a stock’s value drops significantly after disclosure of adverse information, calculating damages typically focuses on the price decline itself, adjusted for market movements. In a new paper, I suggest this …
Initial public offerings (IPOs) are one of the most important events in a firm’s lifecycle, often representing its first major interaction with public capital markets. To assess value, evaluate risks, and determine offering terms, investors, underwriters, auditors, and regulators all …
U.S. Supreme Court Justice Anthony Kennedy observed in the Citizens United decision that shareholders of publicly traded companies could employ the procedures of corporate democracy to ensure that shareholder value was not diverted to political causes and candidates that they …
As more corporate insiders are compensated with their firm’s stock, insider trading becomes more common. However, determining when insiders use private information to guide their trades remains a challenge. Regulators and market participants try to infer whether insiders “know something …
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 …
When I spoke recently about American leadership in the digital finance revolution, I described “Project Crypto” as our effort to match the energy of American innovators with a regulatory framework worthy of them. Today, I would like to outline the …
Between 2020 and the first half of 2024, corporations in a variety of industries adopted the language of social and environmental progress. They pledged to diversify their workforces, hired DEI professionals, denounced racial injustice, and announced plans to reduce greenhouse …
Corporate insiders’ opportunistic trading – particularly selling their firms’ stocks before bad news – erodes public trust, reduces market participation, and exacerbates the agency problem that occurs when the interests of insiders and the company conflict. Yet, regulators have been …
Democratic institutions depend on public confidence to function effectively. Citizens comply with tax laws when they trust the IRS, cooperate with police when they view law enforcement as legitimate, and engage constructively with regulators they perceive as fair and effective. …
In a significant move, the U.S. Securities and Exchange Commission issued a no-action letter advising that it will not recommend enforcement action in respect of Exxon Mobil Corporation’s proposed “Retail Voting Program.” Exxon’s novel Retail Voting Program would be offered …
Following discussions with Davis Polk and other leading capital markets law firms, the SEC posted updated guidance that provides a path forward for companies seeking to IPO during the shutdown. Because the SEC is currently shut down, it cannot declare …
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