Sky Blog
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 …
In April 2025, the landscape of U.S. crypto regulation shifted significantly. Three of the country’s principal bank regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – jointly …
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 …
Whose interests do public pension funds serve? On the one hand, they have a fiduciary duty to maximize value for the pension fund participants whose retirement savings they invest. On the other, they can use their considerable ownership stakes to …
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
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 …
On April 4, 2025, the staff of the SEC’s Division of Corporation Finance (the “Staff”) issued a statement addressing the status of certain stablecoins under the U.S. securities laws.
The statement concludes that a narrow class of USD-backed, fully reserved, …
Good morning and welcome to the annual conference on federal and state securities cooperation, organized jointly by the North American Securities Administrators Association (“NASAA”) and the U.S. Securities and Exchange Commission (“SEC” or “Commission”).[1] Inside the SEC, this gathering …
In an earlier post, I discussed my paper arguing that significant changes to the corporate-disclosure regime should trigger review of aspects of the securities-fraud regime. This is because the disclosure regime and the securities-fraud regime go hand-in-hand. So if …
In a recent study, we examine how political ideology affected SEC commissioners’ stances on whether to adopt the International Financial Reporting Standards (IFRS). Our findings reveal a partisan divide that stalled decision-making and left the U.S. as an outlier in …
Today [March 27], the SEC purports to walk away from the Climate-Related Disclosures Rule.[1] In building the rule, we journeyed up a mountain. The Commission spent at least four years taking input – we issued requests for information, made …
In a new article, we focus on the Securities and Exchange Commission’s enforcement of the CEO and CFO certification requirement pursuant to the Sarbanes-Oxley Act (SOX). The article analyzes the appropriate interpretation of the statute’s reach, the SEC enforcement proceedings …
On March 3, 2025, the staff of the Division of Corporation Finance of the Securities and Exchange Commission (the “SEC”) announced that it will further expand the accommodations available for issuers to submit draft registration statements for nonpublic review. These …