OCC Describes Procedures For Implementing Prompt Corrective Action

The SEC has granted petitions for review of Nasdaq's $5 million MVLS listing standard, keeping the controversial rule on hold while extending the review period for NYSE American's similar market capitalization requirement. Microcap companies trading near these thresholds face potential delisting consequences if these proposed rule changes are ultimately approved, making it critical to understand the compliance strategies and ongoing regulatory developments.

The SEC is proposing to substantively overhaul the securities transfer agent regulatory framework, which has largely remained unchanged since the paperwork-based system of the mid-1970s.

The U.S. Small Business Administration has set new annual fee rates for Small Business Investment Companies' debentures for fiscal year 2027, with standard debentures at 0.3000% and accrual debentures at 0.8710%. These fees apply to any SBIC receiving debenture commitments between October 1, 2026 and September 30, 2027, regardless of when the debentures are actually drawn.

Financial services firms, healthcare organizations, and businesses across industries are investing heavily in AI and data analytics, yet many struggle to translate these investments into measurable returns. The gap between AI ambition and execution often begins with governance, workforce readiness, and the ability to turn insights into actionable business outcomes.

FinCEN has renewed its Geographic Targeting Order for Minnesota, extending enhanced reporting requirements for financial institutions in Hennepin and Ramsey Counties through February 2027. The order mandates detailed recordkeeping for international fund transfers of $3,000 or more, with exemptions for certain lower-risk transactions. What are the compliance implications for banks and money services businesses operating in these jurisdictions?

The SEC's Division of Examinations has identified six critical areas where investment advisers commonly fall short in their annual compliance reviews, from timing failures to inadequate documentation and unimplemented corrective actions. Understanding these deficiencies is essential for advisers seeking to strengthen their compliance infrastructure and avoid examination risks.

The federal banking agencies have proposed new third-party risk management guidance that is more prescriptive than its emphasis on a “risk-based” approach might suggest. In addition to calling for risk-based oversight, the proposal identifies specific elements that banks should address in board-approved policies and throughout the life cycle of third-party relationships, including due diligence, contracting, ongoing monitoring, documentation, remediation, and termination.

Forget what you thought you knew about startup funding. According to Crunchbase, billion-dollar rounds have moved from anomaly to expectation. In the first half of 2026, 60% of global startup funding flowed to rounds of $1 billion or more — and in the U.S., that figure jumped to a staggering 73%.

Federal banking regulators have proposed new interagency guidance that fundamentally reshapes how financial institutions should manage third-party relationships, moving away from process-driven oversight toward risk-based assessments tailored to actual harm potential. The proposal emphasizes that banks should focus resources on relationships presenting genuine financial, operational, or compliance risks rather than applying uniform heightened standards across all vendor arrangements.

The U.S. Senate's failed cloture vote on the Digital Asset Market Clarity Act has prompted a flurry of regulatory activity from federal agencies seeking to establish frameworks for cryptocurrency markets. In response, the SEC issued groundbreaking exemptions for tokenized securities trading, the CFTC extended relief to crypto wallet providers, and Congress advanced new tax legislation for digital assets.

The U.S. Securities and Exchange Commission and the U.S. Food and Drug Administration have signed a Memorandum of Understanding establishing a cooperative framework for interagency information sharing...

As organizations accelerate their adoption of generative AI, attention is increasingly shifting from the technology itself to the contractual frameworks that govern its use. What may appear to be standard licensing language can have significant implications for how businesses leverage AI tools, incorporate AI-generated content into their operations, and pursue future innovation strategies. This article examines one of the more consequential and evolving aspects of generative AI contracting, highlighting are

The Eleventh Circuit's reversal in U.S. ex rel. Zafirov v. Florida Medical Associates addresses one of the most anticipated False Claims Act decisions in years, ruling that qui tam provisions do not violate the Appointments Clause. While this decision aligns with other circuit courts, it leaves critical constitutional questions unresolved, including Take Care and Vesting Clause challenges that could reshape FCA litigation.

President Trump's Executive Order 14421 declares a national emergency targeting foreign-produced equipment in the U.S. bulk-power system, granting the Secretary of Energy sweeping authority to review, restrict, and potentially require replacement of equipment linked to countries under U.S. arms embargoes. While no immediate restrictions take effect, the Order's broad scope encompasses battery storage systems, utility-scale inverters, industrial control systems, and related software, with implementation regu

The OCC and FDIC have jointly finalized a rule that fundamentally redefines what constitutes an "unsafe or unsound practice" in banking supervision, establishing new binding standards for when examiners may issue matters requiring attention. This regulatory shift aims to concentrate supervisory attention on material financial risks rather than procedural deficiencies, while providing banks with stronger grounds to challenge supervisory findings that lack connection to substantive financial harm.

California's Air Resources Board has released comprehensive guidance for entities preparing their first greenhouse gas emissions reports under SB 253, introducing a voluntary reporting platform and clarifying expectations for the November 2026 deadline. The guidance addresses critical questions about data collection requirements, assurance standards, and enforcement discretion for companies that weren't tracking emissions as of December 2024. Understanding these reporting parameters and submission options w

The U.S. Securities and Exchange Commission's new EDGAR Next platform requires all filers, including public companies and Section 16 insiders, to complete annual confirmations to maintain filing access. What are the key deadlines, procedures, and consequences of failing to meet this ongoing compliance requirement that could result in loss of EDGAR access and potential filing delinquencies?

The Delaware Court of Chancery dismissed a class action challenging Vista Equity Partners' take-private acquisition of KnowBe4, Inc., finding that plaintiffs failed to adequately allege a control group among institutional investors and the CEO. The decision examines stringent pleading standards for control groups and demonstrates how a fully informed stockholder vote can cleanse transactions involving director-level conflicts, even when entire fairness review would otherwise apply.

This September 2026 edition of Quorum examines critical developments in corporate governance, M&A transactions, and securities regulation, including Delaware Court decisions on strategic investor rights and control group standards, new SEC guidance on beneficial ownership reporting, and Supreme Court rulings on disgorgement remedies. The newsletter also analyzes FTC perspectives on vertical mergers in defense sectors and provides comprehensive updates on the SEC's 2026 regulatory agenda under Chairman Atkin

The U.S. Supreme Court has unanimously ruled that the SEC may obtain disgorgement without proving investors suffered financial losses, resolving a circuit split in favor of the Commission. While the majority opinion preserves disgorgement as a powerful enforcement tool, Justice Thomas's concurrence raises fundamental questions about whether disgorgement has become a legal remedy triggering Seventh Amendment jury trial rights.