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No-Action Letters

Mayer Brown Free Writings + Perspectives

No-Action Letter on “Group” Reporting under Section 13(d) and 13(g) for Parties to OTC Derivatives Contracts

On January 23, 2026, the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission issued a letter in which it stated it would not object if a large investment bank (the “Bank”) determines...more

Carlton Fields

How to Tokenize Securities: SEC Staff Provides a Taxonomy of Different Approaches

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On January 28, 2026, staff of the SEC Divisions of Corporation Finance, Investment Management, and Trading and Markets issued a joint statement on tokenized securities addressing different approaches they have observed to...more

DLA Piper

SEC Issues Guidance On Tokenized Securities And Related Developments

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The US Securities and Exchange Commission (SEC) released a joint statement on January 28, 2026 clarifying the application of federal securities laws to tokenized securities. This statement, published through the SEC’s...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – February 2026 # 2

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To keep you informed of recent activities, below are several of the most significant federal events that have influenced the Consumer Financial Services industry over the past week....more

Paul Hastings LLP

White House Hosts Crypto Meetings, Treasury Secretary Addresses GENIUS Act Implementation, CFTC Withdraws Event Contracts Guidance...

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The White House Crypto Policy Council convened a meeting with executives and trade associations representing both the crypto industry and traditional financial institutions to discuss legislation on digital asset market...more

Orrick, Herrington & Sutcliffe LLP

SEC official envisions AI modernizing adviser-investor communications

On February 3, SEC Director of the Division of Investment Management Brian Daly addressed how the division is considering the changes and opportunities AI affords investment advisers, investment companies, and investors. Daly...more

Patomak Global Partners

A New Chapter for Shareholder Proposals: Best Practices for Navigating the 2026 Proxy Season

In November 2025, the U.S. Securities & Exchange Commission’s (SEC) Division of Corporation Finance announced that, for the 2025–2026 proxy season, it will no longer issue substantive “no-action” letters for Rule 14a-8...more

Eversheds Sutherland (US) LLP

CFTC Confirms Morgan Stanley Internal Merger Will Not Affect Status Of Legacy Swaps

On January 30, 2026, the Commodity Futures Trading Commission (CFTC) issued Staff Letter 26‑03 (Staff Letter), providing clarity for swap market participants regarding the treatment of certain legacy swaps with two Morgan...more

Eversheds Sutherland (US) LLP

CFTC Extends Compliance Deadline For Amended Large Trader Reporting Requirements

On January 27, 2026, the Commodity Futures Trading Commission (CFTC) issued No-Action Letter No. 26-02 (No Action Letter), granting conditional relief from the compliance deadline for the CFTC’s 2024 amendments to Part 17 of...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

CFTC Provides Interim Relief from Commodity Pool Operator Registration to Certain Investment Advisors

On December 19, 2025, the Market Participants Division (“MPD”) of the Commodities Futures Trading Commission (“CFTC”) issued No-Action Letter No. 25-50, granting interim relief for certain commodity pool operators (“CPOs”)...more

A&O Shearman

CFTC Issues No-Action Relief For Private Fund Managers Pending Potential Reinstatement Of Significant CPO Registration Exemption

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On December 19, 2025, the Market Participants Division (MPD) of the U.S. Commodity Futures Trading Commission (CFTC) issued a no-action letter (Letter) providing certain private fund managers with temporary relief from the...more

Blank Rome LLP

Regulatory Update and Recent SEC Actions (Updated)

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Recent SEC Administration Changes - SEC Announces Departure of OIEA Director Lori J. Schock - The Securities and Exchange Commission (the “SEC”) announced that Lori J. Schock, who had served as the Director of the Office...more

Morrison & Foerster LLP

CFTC Staff Issues No-Action Relief from CPO/CTA Registration for Certain Private Fund Managers and Credit Risk Transfer...

The staff of the Market Participants Division (the “Staff”) of the Commodity Futures Trading Commission (CFTC) have issued two no-action letters that provide targeted relief from commodity pool operator (CPO) and commodity...more

K&L Gates LLP

United States: New Year, New Marketing Rule FAQs

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On 15 January 2026, the SEC staff released two new FAQs addressing issues arising under Advisers Act Rule 206(4)-1 (the Marketing Rule). ...more

K&L Gates LLP

Crypto in 2026: The Democratization of Digital Assets

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The year 2025 saw significant regulatory activity in the realm of digital assets. The US Congress and financial regulators took steps to create and implement a clear legal framework to facilitate financial transactions using...more

Latham & Watkins LLP

Partial US Government Shutdown - SEC Implications

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To quote Bill Murray, “Well, it's Groundhog Day... again...” In other words, it is time to revisit what happens with respect to the SEC if the threatened partial shutdown of the U.S. Government comes to pass...more

Latham & Watkins LLP

SEC Shutdown: FAQs About Removing the Delaying Amendment

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If the US Government shutdown drags on, market participants will start to ask what options are available to get pending deals across the finish line while the SEC is not able to declare registration statements effective....more

Cooley LLP

Corp Fin Director Jim Moloney Talks Disclosure Reform

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New Corp Fin Director Jim Moloney delivered remarks a few days ago at Northwestern’s annual Securities Regulation Institute that are notable – and in line with the theme of Chairman Atkins’ October speech in which he stated...more

Morgan Lewis

CFTC Reinstates CPO and CTA Registration Relief Related to QEPs

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The US Commodity Futures Trading Commission (CFTC) has issued a no-action letter to provisionally relieve a type of private fund manager registered with the US Securities and Exchange Commission (SEC) as an investment adviser...more

Carlton Fields

Expect Focus - Volume I, January 2026

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Just before the October federal government shutdown, the SEC staff issued a no-action letter providing some clarity as to when a state-regulated banking or trust institution can serve as a “qualified custodian” under the...more

Cozen O'Connor

Digital Asset Developments: SEC No-Action Relief for Tokenized Reward Program; NYSE Announces Tokenized Trading Platform

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The new year has started with important developments in the digital asset landscape, as the Securities and Exchange Commission (SEC) and the New York Stock Exchange (NYSE) take action towards integrating digital assets and...more

Cooley LLP

ISS Updates Its FAQs to Align With ‘26 Proxy Guidelines

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Last month, I blogged several times about what ISS changed in its proxy voting guidelines for this proxy season. Now, ISS has updated its three sets of FAQs – consisting of Non-Compensation FAQs; Executive Compensation FAQs;...more

BakerHostetler

Weekly Blockchain Blog - January 2026 #3

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NYSE Developing Tokenized Securities Platform; Chainlink Expands TradFi Data - The New York Stock Exchange (NYSE) recently announced “its development of a platform for trading and onchain settlement of tokenized securities,...more

Carlton Fields

Exxon Mobil’s Retail Voting Program Invites Retail Investors to Join the Choir

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On September 15, 2025, the SEC’s Division of Corporation Finance issued a no-action letter to Exxon Mobil Corp. confirming that it will not recommend enforcement action under the proxy rules regarding the company’s proposed...more

Lowenstein Sandler LLP

Crypto Brief - Lowenstein Crypto Newsletter - January 22, 2026

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On Jan. 21, U.S. Senate Committee on Agriculture, Nutrition, and Forestry Chairman John Boozman, R-Ark., released updated legislative text that builds on a previously released bipartisan discussion draft that would give the...more

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