The Simpson Thacher no-action letter is the first no-action letter issued by the Division of Investment Management that is directly targeted to the crypto asset space

An Alert discussing developments relating to California climate disclosure laws (discussed below) was published on December 10.

On September 27, 2024, the Securities and Exchange Commission (SEC) announced that it was adopting rule and form amendments to its EDGAR filing system. The amendments (referred to as EDGAR Next) are intended to enhance security of the EDGAR system, improve access to and management of EDGAR accounts and modernize connections to the EDGAR platform.

Earlier this week, the SEC, together with the CFTC, proposed amendments to Form PF (the "Proposal").[1] The Proposal, if adopted, would be a welcome change for many sponsors, as the reporting requirements for private fund advisers would become more streamlined and less burdensome and the scope of advisers required to complete all or parts of Form PF would be narrowed.

The U.S. Securities and Exchange Commission (“SEC”) issued an order on April 28, 2026 making inflation-adjusted increases to the dollar amount thresholds for meeting the definition of “qualified client” in Rule 205‑3 under the Investment Advisers Act of 1940 (the “Advisers Act”). These are ordinary course threshold increases made pursuant to the SEC’s obligation under Section 418 of the Dodd-Frank Act to adjust the QC thresholds every five years.

On October 22, 2025, the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") designated two of Russia's largest oil companies—Open Joint Stock Company Rosneft Oil Company ("Rosneft") and Lukoil OAO ("Lukoil")—and certain of their subsidiaries as Specially Designated Nationals ("SDNs").

On April 27, 2026, the staff ("Staff") of the SEC's Division of Investment Management closed that gap by issuing a no-action letter in response to a request from J.P. Morgan Investment Management Inc. ("JPMIM"), confirming that Open-End Registered Funds may rely on an Order as "Regulated Funds," subject to compliance with the Order's terms and conditions.

On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act.

November 2025 witnessed increased industry attention for the European Union's (EU) ongoing efforts to reform the regulatory frameworks applicable to securitisations.

California Governor Gavin Newsom signed the Voluntary Carbon Market Disclosures Act (AB 1305) into law on October 7, 2023, creating a novel disclosure requirement for entities that participate in the voluntary carbon offset market, ...

On October 28, 2024, the U.S. Department of the Treasury ("Treasury") issued a final rule containing the regulations that will make up the new Outbound Investment Security Program (the "Program").

On April 16, 2026, the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (“SEC”) issued an exemptive order granting relief from Rules 13e-4(f)(1)(i) and 14e-1(a) and (b) under the Securities and Exchange Act of 1934, as amended (the “Exchange Act”), for certain qualifying tender offers for equity securities (“10 Business Day Tender Offers”).

On May 4, the U.S. Securities and Exchange Commission (SEC) submitted a proposal to officially rescind its climate-related disclosure rules that would require companies to disclose material climate-related risks and greenhouse gas (GHG) emissions in periodic reports.

On December 18, 2025, President Trump signed the National Defense Authorization Act for Fiscal Year 2026 (the "NDAA").

The SEC Division of Examinations released its 2026 Examination Priorities, providing a first look into the Division's stated focus areas for the new fiscal year.

Companies should take a close look at the transparency of their fees and recurring charges as regulators and the class action bar target misleading pricing practic

On February 4, the U.S. District Court for the Western District of Texas declared Texas' anti-ESG law Senate Bill 13 unconstitutional due to its overbreadth and impermissible vagueness.

The U.S. Securities and Exchange Commission (the “SEC” or “Commission”) has proposed to rescind Rule 206(4)-5 under the Investment Advisers Act of 1940[1] (the “Advisers Act”), commonly known as the “Pay-to-Play Rule”.[2] Issued on September 3, 2026, the proposal (the “Proposal”) follows years of industry advocacy and statements from Commissioners critical of the rule; notably, in the months leading up to the Proposal, Chairman Atkins characterized the rule as “a trap for the unwary.”

On July 21, CARB hosted a public workshop to clarify the near-term implementation path for SB 253, focusing on reporting deadlines, phased Scope 3 reporting, insurance-company treatment, and assurance. During the workshop, CARB introduced a new initial reporting deadline of November 10, 2026 for Scope 1 and Scope 2 emissions reporting, and discussed phased-in Scope 3 reporting beginning in 2027. CARB also signaled that future rules will rely heavily on the GHG Protocol, including disclosures on methodology, boundaries, emissions factors, data sources, and global warming potential values, and previewed expected future application of the climate reporting laws to insurance companies.

On June 24, the California Air Resources Board (CARB) announced a three-month delay of the initial reporting deadline under SB 253 (the Climate Corporate Data Accountability Act) requiring in-scope entities to report Scope 1 and Scope 2 greenhouse gas (GHG) emissions relating to 2025.