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Administrative Procedure Act Rulemaking Process Securities and Exchange Commission (SEC)

Cooley LLP

President Trump Directs Federal Agencies on How to Repeal ‘Unconstitutional’ Rules

Cooley LLP on

On April 11, 2025, a new rule went into effect in which the United States government will start to strictly enforce the requirement that foreign nationals register their presence with U.S. Citizenship and Immigration Services...more

Kramer Levin Naftalis & Frankel LLP

SEC Abandons Climate-Related Disclosure Litigation — What Next?

The Securities and Exchange Commission (SEC) recently informed the U.S. Court of Appeals for the Eighth Circuit that it will no longer defend its March 6, 2024, rule requiring that companies disclose climate-related risks and...more

Cooley LLP

Commissioner Crenshaw decries SEC action pulling the plug on defense of climate disclosure rules

Cooley LLP on

As reported in this PubCo post, the SEC announced yesterday that it was ending its “defense of the rules requiring disclosure of climate-related risks and greenhouse gas emissions”—the climate disclosure rules. In response to...more

Nelson Mullins Riley & Scarborough LLP

No Soup for You - SEC Commissioners Revoke Authority of Director of Enforcement to Launch Investigations

In a famous Seinfeld episode, a master soup maker had strict rules for ordering his delicious confections.  A violation of his rules, resulted in “No soup for you!”...more

Cooley LLP

Acting SEC Chair Uyeda presents blueprint for SEC rulemaking processes

Cooley LLP on

Yesterday, Acting SEC Chair Mark Uyeda delivered remarks to the Investment Company Institute’s 2025 Investment Management Conference. While much of his presentation was specific to investment companies, the theme of his...more

Genova Burns LLC

President Trump to Federal Agencies: “I’ve Got This”

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President Trump’s February 18th Executive Order entitled, “Ensuring Accountability for All Agencies,” represents a sweeping effort to consolidate federal executive branch lawmaking power with the President. The Order’s...more

Bressler, Amery & Ross, P.C.

Coinbase, Inc. v. SEC

In early January, Coinbase achieved a partial victory in the Third Circuit Court of Appeals. Thus, there is hope among crypto companies that the Securities and Exchange Commission (“SEC”) will provide guidelines for...more

Davis Wright Tremaine LLP

New Administration Outlook: A Possible Roadmap to What's Ahead for the CFTC Under New Leadership

On January 20, 2025, the Commodity Futures Trading Commission ("CFTC") unanimously elected Commissioner Caroline D. Pham as acting chairman. The Administration has not yet identified who will be nominated for the position of...more

Troutman Pepper Locke

Third Circuit Demands Greater Clarity from SEC Regarding Digital Asset Regulation

Troutman Pepper Locke on

After two and a half years, Coinbase, Inc. (Coinbase) and other crypto market participants may finally get an answer for why the Securities and Exchange Commission (SEC) has declined to promulgate rules clarifying how and...more

Davis Wright Tremaine LLP

3rd Circuit Rules for Coinbase – Reasoned Analysis and Due Process Do Matter

On January 13, 2024, the U.S. Court of Appeals for the 3rd Circuit ruled on Coinbase's Petition for Review of the SEC's Order denying Coinbase's Petition for Rulemaking requesting that the Commission promulgate rules...more

Kramer Levin Naftalis & Frankel LLP

Third Circuit Chides SEC for Terse Refusal To Engage in Crypto Rulemaking

On Jan. 13, 2025, a unanimous panel of the U.S. Court of Appeals for the Third Circuit held that the Securities and Exchange Commission (SEC or the Commission) violated the Administrative Procedure Act (APA) when it offered...more

Akin Gump Strauss Hauer & Feld LLP

“Under the Wire” E-Comms Settlements: More Confusion Than Closure

On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more

Ropes & Gray LLP

Third Circuit Coinbase Decision Pressures SEC on Crypto Rulemaking

Ropes & Gray LLP on

On Monday, the U.S. Court of Appeals for the Third Circuit issued the attached opinion requiring the SEC to provide a more complete explanation for its refusal to engage in formal notice-and-comment rulemaking regarding the...more

Flaster Greenberg PC

Chevron Deference Decisions and Its Implications on Businesses

Flaster Greenberg PC on

A win for business. The Supreme Court ends Chevron Deference in a spate of recent decisions limiting administrative authority and assisting regulated parties in challenging agency rulemaking. Loper Bright and Relentless-...more

Davis Wright Tremaine LLP

Is the FDIC's Proposed Rulemaking on Brokered Deposit Restrictions a Solution in Search of a Problem?

One of the most fundamental activities of an insured depository institution (IDI) is taking and safekeeping customer deposits. However, a recent proposed rulemaking by the Federal Deposit Insurance Corporation (FDIC) poses...more

Proskauer - The Capital Commitment

Lawsuit Challenges Private Fund Adviser Rules

On Friday, September 1, 2023, a lawsuit was filed with the federal Court of Appeals in the Fifth Circuit challenging the validity and enforceability of the recently adopted Private Fund Adviser Rules under the Investment...more

Akin Gump Strauss Hauer & Feld LLP

Industry Groups Challenge SEC Private Fund Adviser Rule

Earlier today, a coalition of private fund industry organizations filed a petition in federal court seeking judicial review of the “Private Fund Adviser” rule. This rule was adopted by the Securities and Exchange Commission...more

Mayer Brown Free Writings + Perspectives

25 Associations Press US SEC for Longer Comment Periods, APA Compliance for Rulemakings

In an April 5, 2022 letter, 25 trade associations jointly criticized recent US Securities and Exchange Commission (SEC) rulemakings and requested that the SEC provide longer, more appropriate comment periods (and more...more

Allen Matkins

Are Industry Comments The Only Comments That Matter?

Allen Matkins on

Under the federal Administrative Procedure Act's informal rule making mandate, agencies must give interested persons an opportunity to participate in rule making through submission of written data, views, or arguments with or...more

Stinson - Corporate & Securities Law Blog

Court Decision May Slow SEC Approval of SRO Rules

The SEC must generally approve rules and rule changes by self-regulatory organizations, which are referred to as SROs. According to this SEC web page, there are 37 active SROs. The volume of rule filings submitted for...more

Allen Matkins

Even If Enacted, The Choice Act May Not Repeal The SEC’s Pay Ratio Rule

Allen Matkins on

While prognosticators continue to place odds on whether the Financial CHOICE Act of 2017, H.R. 10, will be enacted, many commentators are claiming that it will “repeal” the Securities and Exchange Commission’s pay ratio rule....more

Allen Matkins

“Interim Final Temporary Rules”, Say What?

Allen Matkins on

Visitors to the Securities and Exchange Commission’s website will find a pull-down menu entitled “Regulation”. One of the items on that menu has the oxymoronic title of “Interim Final Temporary Rules”. How can a rule be...more

Allen Matkins

District Court Declines To Redress The SEC’s Failure To Respond To Petition Seeking Political Spending Disclosure Rule

Allen Matkins on

Although placed right up front in the First Amendment to the U.S. Constitution, the right to petition the government for redress of grievances is often overshadowed by the other First Amendment rights. There can be no doubt,...more

Dorsey & Whitney LLP

SEC Enjoined For Failing To Timely Issue Mineral Disclosure Rule

Dorsey & Whitney LLP on

The Dodd-Frank Wall Street Reform Act imposed a requirement on the SEC in Section 1504 to promulgate a disclosure rule regarding certain extraction payments involving resource issuers within 270 days of passage or by April...more

Cooley LLP

Blog: District Court Compels SEC To Provide “Expedited Schedule” For Issuing Dodd-Frank Resource Extraction Rule — Will Other Rule...

Cooley LLP on

A U.S. District Court has handed a victory to Oxfam America in its efforts to compel the SEC to complete rulemaking on the Dodd-Frank mandate regarding resource extraction disclosures (Section 1504). ...more

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