Sky Blog
We oppose rescission of SEC Rule 14a-8.
Rule 14a-8 has for 80 years been a useful, congressionally authorized component of the U.S. capital markets, fully compatible with the long-standing dual state and federal system governing public companies. Reasonable people may …
A growing case law is recognizing private damages claims for market manipulation such as spoofing. A spoofer places orders for an asset while intending to cancel the orders before they execute. The point is to move the price of the …
Executive Summary
Greenwashing is usually treated as a problem of corporate deception. Firms make environmental claims that exaggerate, selectively disclose, or obscure their actual sustainability performance. Greenwashing leaves investors, consumers, employees, and regulators with an overly favorable impression, thereby stifling true progress. …
On September 17, 2026, the Securities and Exchange Commission (the “Commission” or the “SEC”) issued two conditional exemptions to facilitate permissioned trading of tokenized national market system (“NMS”) stocks.[1] Collectively known as the “Innovation Exemption,” the relief exempts qualifying …
On September 15, the Clarity Act failed to secure a cloture vote in the U.S. Senate, with four Republicans and all 47 Democrats voting against considering the bill at this time. The Act may come back to life again next …
Investment in private assets continues to grow, including for an increasing number of registrants that are required to subsequently measure these investments at fair value, such as registered closed-end funds, interval funds, tender offer funds, business development companies and private …
Good morning, ladies and gentlemen. And thank you for joining us today for this public meeting of the Securities and Exchange Commission under the Government in the Sunshine Act.
We have three items on today’s agenda. First, the Commission will …
On September 17, 2026, the U.S. Securities and Exchange Commission (“SEC”) issued an order (sometimes referred to as the “Innovation Exemption”) to address some questions on how to trade public company stock using distributed ledger technology – in other words, …
On September 16, the Securities and Exchange Commission proposed to rescind Rule 14a-8, the SEC rule that lets a shareholder holding as little as $2,000 of stock place a proposal in a company’s proxy statement, at the company’s expense, for …
On September 17, 2026, the U.S. Securities and Exchange Commission (SEC) took a significant step toward integrating tokenized securities into the U.S. equities market by issuing the long-awaited “Innovation Exemption.” The exemption creates a temporary framework that allows certain tokenized …
On September 3, 2026, the Securities and Exchange Commission (SEC) issued a proposal (the Proposal) to rescind Rule 206(4)-5, commonly referred to as the Pay-to-Play Rule (the Rule), in its entirety, eliminating the two-year time-out on compensated advisory services to …
In a new paper, we examine whether the gender composition of companies’ boards affects the Securities and Exchange Commission’s (SEC’s) decision to investigate those companies and, ultimately, to pursue regulatory enforcement.
We consider three related reasons why firms with more …
Empirical evidence shows that investors respond to corporate insiders’ open market purchases by increasing the company’s stock price, reflecting that insiders possess private information indicating that the firm is undervalued. Consistent with that evidence, in a new paper we find …
For a decade, a development team that wanted to distribute tokens in the U.S. or to U.S. persons had two realistic options: attempt an SEC registration that, basically, no one could complete, or make a judgment call under the 1946 …
Today [September 16], the Commission issued two proposing releases related to its proxy rules under the Securities Exchange Act of 1934. The proposals reflect two of my highest regulatory priorities. First, ensuring that the Commission does not improperly intrude into …
Good morning, ladies and gentlemen. I regret that contemporaneous business out of town keeps me from joining you in person today, but I would be remiss not to briefly address this group—albeit pre-recorded—and to thank you for your spirited service …
Both Congress in the Clarity Act and the SEC in Regulation Crypto are moving to redefine the playing field for cryptocurrency. We will address each in a separate statement.
We believe the Clarity Act in the July version is deeply …
Exchange Act Rule 14a-8 addresses when a company must include a shareholder’s proposal in its proxy statement for an annual or special meeting ofshareholders. In order to have a proposal included, a shareholder must be eligible and follow certain procedures …