On February 23, 2026, the SEC, for the first time, granted an exemptive order permitting continuous trading and settlement for an SEC-registered, tokenized government money market fund....more
With this fourth SEC approval, share class ETFs are now ready to go live. Since late 2025, the SEC has provided exemptive relief to dozens of managers under Section 18(f), among other provisions, for mutual funds to...more
Effective March 18, 2026, directors and officers (“D&Os”) of foreign private issuers (“FPIs”) with a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934, as amended (the “Exchange...more
On February 27, 2026, the Securities and Exchange Commission (the SEC) adopted final rules to enact the requirements of the Holding Foreign Insiders Accountable Act (HFIA Act). These final rules, which mark a significant...more
In February 2026, the Securities and Exchange Commission (SEC) approved and the Financial Industry Regulatory Authority (FINRA) adopted amendments to FINRA Rule 3220 (Influencing of Rewarding Employees or Others),...more
As previously reported in our advisory, the "Holding Foreign Insiders Accountable Act" (the HFIAA) caused directors and officers of foreign private issuers (FPIs) with equity securities registered under the US Securities...more
The SEC has adopted a final rule implementing the Holding Foreign Insiders Accountable Act that, effective March 18, 2026, subjects directors and officers of foreign private issuers to the insider ownership reporting regime...more
The recently enacted Holding Foreign Insiders Accountable (HFIA) Act was designed to make the holdings and transactions of directors and officers of foreign private issuers (FPIs) more transparent. Our Securities Group breaks...more
On March 5, 2026, the U.S. Securities and Exchange Commission (SEC or Commission) issued an exemptive order relieving directors and officers of certain foreign private issuers (FPIs) from the Section 16(a) reporting...more
On March 5, 2026, the U.S. Securities and Exchange Commission (the “SEC”) issued an exemptive order under Section 16(a)(5) of the U.S. Securities Exchange Act of 1934 (the “Exchange Act”)....more
As discussed in our prior post, the Holding Foreign Insiders Accountable Act, adopted on December 18, 2025, eliminated the exemption to the Section 16(a) reporting requirements for directors and officers of foreign private...more
On March 5, 2026, the U.S. Securities and Exchange Commission ("SEC") issued an order (the "Exemptive Order") that provides a conditional exemption from the reporting requirements of Section 16(a) of the Securities Exchange...more
On March 5, 2026, in advance of the March 18th compliance deadline, the U.S. Securities and Exchange Commission (“SEC”) issued an order granting directors and officers of certain foreign private issuers (“FPIs”) an exemption...more
On February 27, 2026, the Securities and Exchange Commission (SEC) adopted final amendments to implement the Holding Foreign Insiders Accountable Act (HFIAA), which amended Section 16(a) of the Securities Exchange Act of 1934...more
On March 5, 2026, the Securities and Exchange Commission (the SEC) issued an order exempting directors and officers of certain foreign private issuers (FPIs) in Canada, Chile, the European Economic Area, the Republic of...more
On March 5, 2026, the SEC issued Release No. 34-104931, granting conditional exemptive relief from the Section 16(a) reporting requirements for directors and officers of certain foreign private issuers (FPIs). ...more
On March 5, 2026, the Securities and Exchange Commission (the “SEC”) published an order granting an exemption from beneficial ownership reporting requirements under Section 16(a) of the Securities Exchange Act of 1934 (the...more
Here’s a note that Cooley’s Courtney Thorne posted on LinkedIn yesterday: “Less than an hour ago, the SEC issued an exemptive order – Release No. 34-104931 – granting conditional relief from the Section 16(a) insider...more
Good news! The SEC has issued exemptive relief under the Holding Foreign Insiders Accountable Act (the HFIAA). For those of you focused on more important things in life, like Major League Baseball’s opening day later this...more
On December 3, 2025, the United States Securities and Exchange Commission (SEC) issued an exemptive order (the “Order”) further delaying the implementation and compliance for short-sale and securities-lending reporting rules...more
Who may be interested: Registered Investment Companies; Boards of Directors; Investment Advisers - Quick Take: Guinness Atkinson Funds, with the counsel of Seward & Kissel, has submitted an application seeking an exemptive...more
At age 79, Paul Anka, the crooner and songwriter, is more relevant than ever. In 2020, he appeared on Season 4 of “The Masked Singer,” enjoyed a popular resurgence courtesy of TikTok, reworked his anthem “My Way” for the...more
On October 7, 2020, the Securities and Exchange Commission (SEC) adopted Rule 12d1-4 (Final Rule or Rule 12d1-4) under the Investment Company Act of 1940 (1940 Act) in an effort to streamline and enhance the regulatory...more
The proposal would significantly impact finders by granting tailored exemptive relief to individuals engaging in limited capital raising activity. Key Points: ..The Proposal would provide a conditional exemption that...more
Today, the SEC published in the Federal Register a proposed notice of an exemptive order (the “Proposal”) that would, subject to limitations and conditions discussed below, exempt certain individuals seeking to find investors...more