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
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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,
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
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 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
The SPV Series: Practical and Structuring Considerations for Multi-Layer SPVs
Given the continued and growing interest in special purpose vehicles (“SPVs”) as a means of accessing private market investments, we are publishing a series of posts that examine different aspects of these structures. This is our third post in the
SEC Staff Issues No-Action Relief for “Zero Cash Balance” Brokerage Account Models
On September 17, 2026, the Staff of the Division of Trading and Markets (the “Division”) of the Securities and Exchange Commission (the “SEC”) issued two no-action letters addressing the net capital and customer protection implications of “zero cash balance” brokerage
Proposed Expansions to the Accredited Investor Definition for Natural Persons
Earlier this week, the Securities and Exchange Commission continued to implement its capital-formation agenda by publishing a number of notices aimed at modernizing the definition of “accredited investor,” including introducing the possibility of a long-discussed accredited investor exam.
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SEC Proposes Expansion of Accredited Investor Definition
On September 30, the Securities and Exchange Commission (the “Commission” or the “SEC”) published a number of notices aimed at modernizing the definition of “accredited investor,” including the possibility of a long-discussed accredited investor exam.
In their proposals, the Commission
SEC Proposes Amendments That Address Retailization and Modernize Regulated Funds
On September 30, 2026, the Securities and Exchange Commission (the “SEC”) proposed amendments intended to provide additional flexibility for regulated funds and their investment advisers. The proposals address performance-based compensation, interval fund repurchase requirements and multiple share classes for registered