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Katten Muchin Rosenman LLP

Confidential Treatment for Advisers Act Filings: Process Changes and Practical Takeaways

Investment advisers may request confidential treatment of certain information in Form ADV and other filings under the Investment Advisers Act of 1940 (Advisers Act), which currently only the Commission itself has the...more

Katten Muchin Rosenman LLP

FinCEN Finalizes 2028 Compliance Date for Adviser AML Programs

On December 31, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a two‑year delay of the effective date for the anti-money laundering/counter-financing of terrorism (AML/CFT)...more

Winstead PC

SEC’s Division of Corporate Finance: 506(c) Interpretative Guidance

Winstead PC on

Under Regulation D Rule 506(c) of the Securities Act of 1933, private funds may generally solicit and advertise their offerings, but all purchasers must be verified as accredited investors before being allowed to invest. ...more

Proskauer - Regulatory & Compliance

FinCEN Finalizes Two‑Year Delay of the Investment Adviser AML Rule; Reaffirms Intent to Further Review and Tailor the Rule, and to...

FinCEN has now adopted its previously‑proposed two‑year delay in the effective date for the investment adviser AML rule (including the requirements to establish AML programs and file SARs) until January 1, 2028. FinCEN...more

Walkers

EU CryptoReg Roundup: December 2025

Walkers on

Welcome to our EU crypto update - a roundup of key Irish and EU legislative and regulatory developments shaping the crypto-asset sector....more

Thomas Fox - Compliance Evangelist

Daily Compliance News: January 15, 2026, The Do You Need a Second CCO Edition

Welcome to the Daily Compliance News. Each day, Tom Fox, the Voice of Compliance, brings you compliance-related stories to start your day. Sit back, enjoy a cup of morning coffee, and listen in to the Daily Compliance News....more

K&L Gates LLP

President Trump Issues Executive Order Limiting Stock Buybacks and Dividends for Defense Contractors

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On 7 January 2025, President Donald Trump issued an executive order (EO) aimed at limiting and preventing certain large defense contractors from conducting stock buybacks, issuing dividends, and awarding executive...more

Haynes Boone

Reminder of Annual Reporting and IRS Filings for ISO Exercises and ESPP Stock Transfers

Haynes Boone on

Employers sponsoring equity incentive plans or tax-qualified employee stock purchase plans (“ESPP”) must fulfill certain year-end information reporting requirements under Section 6039 of the Code with respect to company stock...more

Mayer Brown Free Writings + Perspectives

Staff Report from the Office of the Advocate for Small Business Capital Formation: Part II

IPOs and Small Public Companies As we noted in our prior post, the Office of the Advocate for Small Business Capital Formation recently issued its Staff Report for fiscal year 2025, which provides information on the Office’s...more

Morgan Lewis

Nasdaq Expands Discretionary Authority to Deny Initial Listings Based on Manipulation Risk

Morgan Lewis on

Effective December 19, 2025, Nasdaq Rule IM-5101-3 introduces a risk-based framework permitting Nasdaq to deny initial listings based on perceived susceptibility to manipulation, including risks arising from third-party...more

Orrick, Herrington & Sutcliffe LLP

Risk and Reward: How Starting Your Business as an LLC Could Impact QSBS Tax Savings (UPDATE)

As a founder, deciding whether to organize your business as a corporation or a limited liability company (LLC) is a crucial first step. Corporations are often favored for their ability to attract venture capital and offer...more

Pillsbury - Global Trade & Sanctions Law

Taking a Closer Look at the COINS Act

The Fiscal Year 2026 National Defense Authorization Act, signed into law on December 18, 2025, includes the Comprehensive Outbound Investment National Security Act of 2025 (COINS Act), which establishes a statutory framework...more

Hogan Lovells

Foreign private issuer directors and officers now subject to Exchange Act Section 16(a)

Hogan Lovells on

On December 18, 2025, President Trump signed into law the Holding Foreign Insiders Accountable Act (the Act), which amends Section 16(a) of the Securities Exchange Act of 1934 to require directors and officers of publicly...more

Goldberg Segalla

SEC Clarifies Custody of Crypto Assets by Broker-Dealers

Goldberg Segalla on

The United States Securities and Exchange Commission (SEC) on Dec. 17 issued a statement noting its position on the applicability of Rule 15c3-3 regarding broker-dealers that hold crypto asset securities, including such...more

Cooley LLP

New Short Position Reporting Requirements: Initial Filings Due February 17, 2026

Cooley LLP on

Institutional investment managers, including venture and private equity funds and other institutional investors, that engage in the short selling of equity securities should be mindful of the Securities and Exchange...more

DLA Piper

Updating Form 10-K for fiscal year 2025 and other annual reporting

DLA Piper on

Now that 2026 has begun, United States public companies with a December 31 fiscal year-end will be working to prepare their annual reports on Form 10-K for filing with the US Securities and Exchange Commission (SEC). ...more

FBT Gibbons LLP

After Ninth Circuit’s SB 261 Oral Argument: Where First Amendment Line May Land for Climate-Risk Disclosure

FBT Gibbons LLP on

On January 9, 2026, the U.S. Court of Appeals for the Ninth Circuit heard oral argument in Chamber of Commerce of the United States of America, et al. v. Sanchez, No. 25-5327 (9th Cir.), challenging California’s climate...more

Bressler, Amery & Ross, P.C.

FINRA Proposes Rule Changes Designed to Help Member Firms Combat Financial Exploitation of Seniors and Other Investors

On January 8, 2026, FINRA issued Regulatory Notice 26-02 announcing proposals for a new rule and revisions to two existing rules. FINRA seeks to revise Rule 4512’s provisions regarding trusted contact persons, to increase...more

American Lending Center

ALC’s 2026 EB-5 Market Outlook: Top 10 EB-5 Trends You Can’t Ignore

The EB-5 market is set for another milestone year in 2026, and the American Lending Center (ALC) is continuing our focus on Immigrant First Investing....more

Katten Muchin Rosenman LLP

Defining Small: SEC Proposal Could Shift Regulatory Burdens for Advisers and Investment Companies

On January 7, the Securities and Exchange Commission (SEC) proposed amendments (the Proposal) to raise the small entity thresholds for purposes of the Regulatory Flexibility Act (RFA) for investment companies and advisers....more

White & Case LLP

Key considerations for the 2026 annual reporting and proxy season: your upcoming Form 20-F and other FPI-specific considerations

White & Case LLP on

This memorandum outlines key considerations from White & Case’s Public Company Advisory Group for foreign private issuers (“FPIs’”) during the 2026 annual reporting season, divided into two sections: Form 20-F art I: Top...more

McDermott Will & Schulte

Defense contractors face ban on stock buybacks and dividends

On January 7, 2026, the White House issued a sweeping new executive order (EO) titled “Prioritizing the Warfighter In Defense Contracting.” It declares, “Effective immediately, [underperforming defense contractors] are not...more

Cooley LLP

The SEC (Broadly) Solicits Comment on the Entirety of Regulation S-K

Cooley LLP on

Yesterday, SEC Chairman Paul Atkins issued this statement soliciting comments on the entirety of Regulation S-K, “with the goal of revising the requirements to focus on eliciting disclosure of material information and avoid...more

Skadden, Arps, Slate, Meagher & Flom LLP

Capacity Over Dividends: Prioritizing the Warfighter in Defense Contracting

On January 7, 2026, President Donald Trump issued a new executive order (EO) aimed at realigning defense contractors’ incentives to prioritize domestic investment, timely delivery and quality over investor returns....more

Cooley LLP

Year-End Reporting for ISO Exercises and ESPP Stock Transfers - January 2026

Cooley LLP on

This alert serves as a reminder of certain year-end reporting requirements imposed under Section 6039 of the Internal Revenue Code (IRC) of 1986, as amended, with respect to: Incentive stock option (ISO) exercises by current...more

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