Pursuant to the general instructions to Form S-3, an issuer must have been subject to the reporting requirements of Section 12 or 15(d) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), for at least the prior
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Amendments to FINRA Rule 2210 Permit Use of Projected Performance and Targeted Returns in Broker-Dealer Communications Subject to Specified Conditions
On October 15, 2026, the Securities and Exchange Commission (“SEC”) approved amendments to Rule 2210 (Communications with the Public) of the Financial Industry Regulatory Authority, Inc. (“FINRA”), allowing member firms to project performance or provide a targeted return with respect
FINRA Amends Rules 5110 and 5123; SEC Approves CIT Exemption
On October 21, 2026, the Financial Industry Regulatory Authority, Inc. (“FINRA”) published Regulatory Notice 26-19 announcing amendments to FINRA Rule 5110 (Corporate Financing Rule – Underwriting Terms and Arrangements) and Rule 5123 (Private Placements of Securities). The amendments are part
SEC Staff of the Division of Trading and Markets Issues FAQs on the Innovation Exemption
On October 20, 2026, the Staff of the Division of Trading and Markets (the “Division”) of the Securities and Exchange Commission (the “SEC”) published frequently asked questions (the “FAQs”) regarding the SEC’s September 17, 2026 order (the “Innovation Exemption Order”).
New CFIs on Instruction 4 to Item 2.01 of Form 8-K (and Some Clean-up Changes)
On October 21, 2026, the Staff of the Securities and Exchange Commission’s Division of Corporation Finance published a handful of new Corporation Finance Interpretations, or CFIs, as well as revised and withdrew some previously existing CFIs. The Staff has done
SEC Proposes Expanding Securities Eligible for Cross Trading by Registered Funds
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”)
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,
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