On October 9, 2026, the Securities and Exchange Commission proposed amendments to Rule 17a-7 under the Investment Company Act of 1940, as amended, that would expand the types of securities eligible for cross trading between registered investment companies (“registered funds”)
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SEC Staff Publishes New CFIs Regarding the Use of Form S-8
On October 15, the Staff of the Securities and Exchange Commission’s Division of Corporation Finance published several new Corporation Finance Interpretations, or CFIs, most of which relate to the use of Form S-8, the short-form registration statement used to register…
The Evolving Structured Products Disclosure Framework and Regulatory Developments on the Horizon
Webinar | October 26, 202611:00 a.m. – 11:30 a.m. EDT | 3:00 p.m. – 3:30 p.m. GMT | 4:00 p.m. – 4:30 p.m. CETRegister here.
The US regulatory landscape for structured products continues to evolve, bringing new opportunities, considerations,…
SEC Investigative Report Addresses Possible Schedule 13D Reporting Obligations Incurred Through Participation in Investor Organizations
In a somewhat surprising development, on October 7, 2026, the Securities and Exchange Commission’s Division of Enforcement (the “Division”), in consultation with the Division of Corporation Finance, published an investigation report (the “Report”) pursuant to Section 21(a) of the Securities…
New CFIs on Standing Voting Instructions in Retail Voting Programs
On October 8, 2026, the Securities and Exchange Commission’s Division of Corporation Finance (the “Division”) published two new Corporation Finance Interpretations, or CFIs, addressing retail voting programs. Retail voting has been a popular topic for the Division lately, including two…
CFTC Draws the Line: Interim Final Rule Excludes Certain Gaming Products from, and Proposed Rule Includes Event Contracts in, the “Swap” Definition
On October 9, 2026, the Commodity Futures Trading Commission (“CFTC”) took two coordinated actions addressing the scope of its jurisdiction over event contracts. First, it issued an interim final rule (the “Interim Final Rule”) codifying its longstanding position that gambling…
Nasdaq Eliminates Sub-$4 Initial Listing Path on the Nasdaq Capital Market
On October 7, 2026, the Securities and Exchange Commission (the “SEC”) posted notice of Nasdaq’s proposed rule change (File No. SR-NASDAQ-2026-082) to amend Nasdaq Listing Rule 5505 to require a minimum $4 price in all instances for initial listings on…
The SEC as a Commission of One…
Effective on October 2, 2026, the Securities and Exchange Commission (the “Commission”) modified its quorum requirement, as set forth in SEC Organizational Rule 41 (“Rule 41”). The rule remains unchanged in that it continues to provide that three commissioners constitute…
SEC Gives the Greenlight to Retail Investor Voting Programs
The Office of Mergers and Acquisitions in Securities and Exchange Commission’s (the “Commission”) Division of Corporation Finance recently published two no-action letters agreeing not to recommend enforcement action related to certain Exchange Act rules as applied to retail investor voting…
SEC Proposes Amendments Addressing Retailization; Modernizing Regulated Funds and Performance-Based Compensation
On September 30, 2026, the Securities and Exchange Commission (the “SEC”) issued two proposing releases containing amendments that would materially affect how business development companies (“BDCs”) that have elected to be regulated under the Investment Company Act of 1940, interval…