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Constitutional Challenges Securities and Exchange Commission (SEC)

Allen Matkins

Issuer Retreats From Racial Share Allocation Scheme

Allen Matkins on

In February, I wrote about a proposed offering that involved a racially based share allocation scheme. Last month, it appeared that the offering was stalled at the Securities and Exchange Commission. Recently, the company,...more

Mintz - Energy & Sustainability Viewpoints

Sustainable Energy & Infrastructure Litigation Updates — May 2025

Federal Regulation On April 8, 2025, President Trump issued an executive order that sought to target actions undertaken by individual US states to combat climate change, for the stated purpose of ensuring “American energy...more

Baker Donelson

Red Tape or Green Future? Unpacking California's Climate Disclosure Laws and the Pushback

Baker Donelson on

As the federal government works to roll back climate regulations and climate-focused initiatives, states are developing avenues to fill in the gaps left behind. In 2024, the Securities and Exchange Commission (SEC) adopted...more

Troutman Pepper Locke

White House Issues Memorandum Directing Federal Agencies to Repeal Regulations Deemed to be Unlawful Pursuant to Recent U.S....

Troutman Pepper Locke on

On April 9, the White House issued a memorandum directing federal executive departments and agencies to repeal regulations deemed unlawful pursuant to certain U.S. Supreme Court decisions. This directive aims to address...more

Woods Rogers

Repeal, Not Replace: President Trump’s Directive To Deregulate

Woods Rogers on

On April 9, 2025, President Trump issued a Presidential Memorandum titled “Directing the Repeal of Unlawful Regulations,” marking a significant step in the Administration’s push to deregulate under the broader DOGE...more

Allen Matkins

Intentionally Discriminatory Public Offering Stalled At The SEC

Allen Matkins on

In this February post, I pondered the question of whether an issuer could allocate shares on the basis of race, gender or ethnicity.  That post was inspired by the case of  Glennon v. Johnson, U.S. Dist. Ct. Case No....more

Wilson Sonsini Goodrich & Rosati

SEC Votes to End Defense of Climate Disclosure Rules

On March 27, 2025, the SEC announced that it voted (2-1) to end its defense of the final enhanced and standardized climate-related disclosure rules (the Climate Rules). The SEC previously adopted the Climate Rules on March 6,...more

Cooley LLP

Surprise—not! SEC votes to terminate defense of climate disclosure rules

Cooley LLP on

Yesterday, the SEC announced that the Commissioners had voted to end the SEC’s “defense of the rules requiring disclosure of climate-related risks and greenhouse gas emissions”—the climate disclosure rules. As you probably...more

Vinson & Elkins LLP

Federal Climate Change Disclosures No More

Vinson & Elkins LLP on

In a move that perhaps comes as no surprise, on March 27, 2025, the Securities and Exchange Commission (“SEC” or “the Commission”) issued Press Release 2025-58 announcing it had voted to end its defense of its climate-related...more

Frost Brown Todd

Sick of ALJs? The New Right to Federal Court During Agency Prosecutions

Frost Brown Todd on

Practitioners and scholars all agree that last summer, the U.S. Supreme Court overhauled the administrative state. And no, not simply by overturning Chevron, which was undoubtably the most significant decision of the Supreme...more

Goodwin

2024 Year in Review: Major US Supreme Court and Appellate Cases

Goodwin on

Welcome to the “Major US Supreme Court and Appellate Cases” chapter of our annual report, Consumer Financial Services: 2024 Year in Review. The Supreme Court continues to take a close look at major administrative law...more

Orrick, Herrington & Sutcliffe LLP

District court dismisses bank’s constitutional challenge to FDIC administrative proceedings

On March 3, the U.S. District Court for the District of Kansas dismissed a constitutional challenge to enforcement proceedings by the FDIC, ruling the court lacked subject matter jurisdiction over the plaintiff’s claims. As...more

Holland & Knight LLP

DOJ Forsakes Defending the ALJ Process Against Article II Challenges

Holland & Knight LLP on

On Feb. 18, 2025, in a case seeking declaratory and injunctive relief against the SEC, the U.S. Department of Justice (DOJ) filed a Notice of Change in Position indicating that the DOJ will no longer defend in litigation "the...more

DLA Piper

Executive Order on Federal Agencies

DLA Piper on

On February 18, 2025, President Donald J. Trump signed an Executive Order (EO), entitled, “Restoring Democracy and Accountability in Government,” which asserts greater authority over all federal agencies, including those...more

K&L Gates LLP

Trump Administration Asserts Control Over Independent Agencies

K&L Gates LLP on

The Trump administration has taken two actions that will dramatically increase White House control over federal commissions, boards, and officials that were previously considered independent. These actions are likely to...more

Womble Bond Dickinson

Decoding the Independent Agency Executive Order: Implications for the Activities of Federal Agencies and Business Interests

Womble Bond Dickinson on

The Ensuring Accountability for All Agencies Executive Order (the “Independent Agency EO”), signed by President Trump on February 18, extends unprecedented direct Administration control over independent regulatory agencies,...more

Genova Burns LLC

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

Genova Burns LLC on

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

Orrick, Herrington & Sutcliffe LLP

DOJ determines administrative law judges are unconstitutional

On February 20, Acting Solicitor General Sarah M. Harris wrote to Sen. Charles Grassley (R-IA), President pro tempore of the Senate, and Rep. Mike Johnson (R-LA), Speaker of the House, to disclose that, pursuant to 28 U.S.C....more

Katten Muchin Rosenman LLP

President Trump Executive Order on Supervision of 'Independent' Agencies

Amidst a blitz of executive action, on February 18, President Donald Trump signed an executive order entitled “Ensuring Accountability for all Agencies” (Executive Order) exerting more direct control over “independent...more

Carlton Fields

DOJ Withdraws Defense of SEC ALJs' Constitutionality as Trump Issues Executive Order on Agency Accountability

Carlton Fields on

On February 18, 2025, President Trump issued executive order 14215, titled “Ensuring Accountability for All Agencies,” with the stated purpose of making federal agencies, including independent regulatory ones like the...more

Sheppard Mullin Richter & Hampton LLP

Trump Executive Order Requires Independent Agencies to Submit Regulations for Presidential Review

On February 19, 2025, President Donald Trump signed an executive order (the “Order”) mandating that independent agencies, including the SEC, the FCC, and the FTC, submit proposed regulations for presidential review before...more

Perkins Coie

Executive Order Expands Presidential Oversight of Independent Agencies

Perkins Coie on

President Donald Trump recently signed a new executive order that confirms the administration’s legal position that so-called independent regulatory agencies operate under the control of the White House. Executive Order...more

Cooley LLP

Executive Order deletes “independent” from “independent regulatory agencies”

Cooley LLP on

On Tuesday, the President signed a new Executive Order claiming that “independent” federal regulatory agencies, such as the SEC, shouldn’t really be so independent after all. Rather, the Order contends, they all should be...more

Allen Matkins

May Corporations Allocate Shares Based On Race, Gender, Or Ethnicity?

Allen Matkins on

Last December, Bally’s Chicago, Inc., a Delaware corporation and indirect subsidiary of Bally’s Corporation filed a registration statement with the Securities and Exchange Commission to raise funds in connection with the...more

Barnea Jaffa Lande & Co.

Court Ruling on SEC’s Crypto Regulation Approach: A Turning Point?

For years, the crypto industry has faced regulatory uncertainty, with the Securities and Exchange Commission (SEC) relying on “regulation by enforcement” rather than establishing specific rules for digital assets. Coinbase,...more

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