SEC GUIDANCE AND OTHER ACTIVITIES

SEC Small Business Advisory Committee – Regulatory Framework for Finders and Regulation A

On July 22, 2025, the SEC Small Business Capital Formation Advisory Committee held a meeting exploring Regulation A and the topic of “finders,” persons who assist companies with limited capital-raising activities in private markets.

The press release announcing the meeting is available here:

https://www.sec.gov/newsroom/meetings-events/sbcfac-meeting-072225

The webcast of the meeting is available here:

https://www.sec.gov/about/advisory-committees/small-business-capital-formation-advisory-committee#meetings

SEC Announces Roundtable on Trade-Through Prohibitions

On July 21, 2025, the SEC announced it will host a roundtable on September 18, 2025, to discuss trade-through prohibitions in the National Market System (NMS) stock and listed options markets. The roundtable will be open to the public and streamed live on SEC.gov, and a recording will be posted at a later date.

The press release is available here:

https://www.sec.gov/newsroom/press-releases/2025-99-sec-announces-roundtable-trade-through-prohibitions

Compliance and Disclosure Interpretations: Section 13(d) and 13(g)

On July 11, 2025, the SEC issued a Compliance and Disclosure update regarding Exchange Act Sections 13(d) and 13(g) and Regulation 13D-G regarding beneficial ownership reporting.

The update is available here:

https://www.sec.gov/about/divisions-offices/division-corporation-finance/cdi-07112025

Updates to the Financial Reporting Manual

On July 2, 2025, the Division of Corporation Finance provided informal staff interpretations to the Financial Reporting Manual (FRM). An updated version of the FRM has been posted to reflect the 2020 amendments to the S-X Acquisition Rules (S-X 3-05, S-X 3-14, S-X 8-04, and S-X 8-06) and S-X Article 11, along with other minor updates.

A summary of the most recent changes is available here:

https://www.sec.gov/about/divisions-offices/division-corporation-finance/financial-reporting-manual

SEC Office of the Investor Advocate (OIAD) Report on Objectives: Fiscal Year 2026

The SEC OIAD has published its report on objectives for fiscal year 2026, including a review of disclosure effectiveness, China-based variable interest entities, private markets investments in retirement accounts, evaluating the potential impact of SRO rules proposals on investors, and considering investor comments and initiatives of the crypto task force.

A pdf of the report is available here:

https://www.sec.gov/files/fy26-oiad-sar-objectives-report.pdf

SEC Extends Compliance Date to Help Broker-Dealers Fully Test and Implement Daily Reserve Computation Requirement

On June 25, 2025, the SEC voted to extend the compliance date to June 30, 2026, for the amendments to Rule 15c3-3 (the broker-dealer customer protection rule), which the Commission adopted on Dec. 20, 2024. The amendments require certain broker-dealers to increase the frequency of required reserve computations under Rule 15c3-3 from weekly to daily; the compliance date for these required daily reserve computations was originally Dec. 31, 2025.

Compliance Date: Extended to June 30, 2026

The press release is available here:

https://www.sec.gov/newsroom/press-releases/2025-95-sec-extends-compliance-date-help- broker-dealers-fully-test-implement-daily-reserve-computation

CRYPTO

White House

The President’s Working Group on Digital Asset Markets Releases Recommendations

On July 30, the White House Working Group on Digital Assets released their report with “Recommendations to Strengthen American Leadership in Digital Financial Technology.” The recommendations include 7 sections: Digital Asset Ecosystem, Digital Asset Market Structure, Banking and Digital Assets, Stablecoins and Payments, Countering Illicit Finance, and Taxation.

The Fact Sheet is available here:

https://www.whitehouse.gov/fact-sheets/2025/07/fact-sheet-the-presidents-working-group-on-digital-asset-markets-releases-recommendations-to-strengthen-american-leadership-in-digital-financial-technology/

The full Report is available here:

https://www.whitehouse.gov/wp-content/uploads/2025/07/Digital-Assets-Report-EO14178.pdf

Legislation

Senate Publishes Market Structure Discussion Draft and Request for Information (RFI)

On July 22, 2025, the U.S. Senate published a discussion draft of the Responsible Financial Innovation Act of 2025 as a bill to solicit public feedback. This bill expands on the CLARITY Act by providing for the regulation of crypto assets by outlining agency jurisdictions over types of crypto assets and ancillary assets; the bill also provides for the establishment of customer protection and market integrity authorities, upon approval by the SEC and the CFTC.

The discussion draft of the Responsible Financial Innovation Act of 2025 is available here:

https://www.congress.gov/bill/118th-congress/senate-bill/2281/text

The RFI is available here:

https://www.banking.senate.gov/imo/media/doc/market_structure_rfi.pdf

House Passes Digital Asset Market Clarity Act of 2025 (the “CLARITY Act”)

On July 17, 2025, the House passed the CLARITY Act of 2025 (HR 3633). The Act establishes a regulatory framework for digital commodities, defined by the bill as digital assets that rely upon a blockchain for their value. The Senate has begun their work on their version of a crypto market structure bill.

The CLARITY Act is available here:

https://www.congress.gov/bill/119th-congress/house-bill/3633/text

Chair Atkins Statement on GENIUS Act Signed Into Law:

Statement is available here.

SEC Actions

SEC Crypto Task Force Outreach

On August 1, the SEC announced and that its Crypto Task Force will host a series of roundtables across the country to provide opportunities for additional stakeholders to meet with Commissioner Hester Peirce, who leads the Crypto Task Force. The schedule is included in the announcement with dates from August to December. The schedule is included in the announcement with dates from August to December. The announcement states that, “[t]hey are particularly interested in hearing from representatives of crypto-related projects that have 10 or fewer employees and are less than two years old.”

The announcement is available here with additional details:

https://www.sec.gov/newsroom/press-releases/2025-102-road-sec-crypto-task-force-host- series-roundtables-across-us?utm_medium=email&utm_source=govdelivery

SEC Announces “Project Crypto”

On July 31, SEC Chair Atkins announced Project Crypto “directing the SEC’s policy divisions to work with the Crypto Task Force, led by Commissioner Peirce, to swiftly develop proposals to implement the PWG’s recommendations”, adding that “Project Crypto will involve a broad range of initiatives across the Commission.”

Chair Atkin’s Statement is available here:

https://www.sec.gov/newsroom/speeches-statements/atkins-digital-finance-revolution- 073125?utm_medium=email&utm_source=govdelivery#_ftn22

SEC Permits In-Kind Creations and Redemptions for Crypto ETPs

On July 29, the SEC Commission voted to approve orders to permit in-kind creations and redemptions by authorized participants for crypto asset exchange-traded product (ETP) shares.

The press release is available here:

https://www.sec.gov/newsroom/press-releases/2025-101-sec-permits-kind-creations-redemptions-crypto-etps

Division of Corporation Finance Issues Statement on Crypto Asset Exchange-Traded Products

On July 1, 2025, the SEC Division of Corporate Finance published its views on the application of certain disclosure requirements under the federal securities laws to offerings and registrations of securities by issuers of crypto asset exchange-traded products (“crypto asset ETPs”). The statement addresses the division’s views about certain disclosure requirements set forth in Regulation S-K and Regulation S-X as they apply to registration forms (such as Form S-1).

The statement is available here:

https://www.sec.gov/newsroom/speeches-statements/cf-crypto-asset-exchange-traded-products-070125

FINRA

FINRA Foundation Releases Sixth Wave of the National Financial Capability Study

On July 16, 2026, FINRA released its sixth wave of the National Financial Capability Study, including data and insights about the financial lives of U.S. adults conducted. The study is conducted every three years, the first in 2009.

The study is available here:

https://www.finra.org/media-center/newsreleases/2025/finra-foundation-releases-sixth-wave-national-financial-capability

FINRA Publishes 2025 Industry Snapshot

On July 9, 2025, FINRA published its 2025 Industry Snapshot, its annual statistical report on registered representatives, brokerage firms and market activity the organization oversees.

The 2025 Industry Snapshot is available here:

https://www.finra.org/media-center/newsreleases/2025/finra-publishes-2025-industry-snapshot

RETIREMENT

DOL Removes Annuity Provider Safe Harbor

The 2008 fiduciary safe harbor allowed for the selection of annuity providers for the purpose of benefit distributions from individual account retirement plans. The DOL explained this action would reduce “unnecessary burdensome and costly Federal regulations” and “[t]he regulatory safe harbor became unnecessary in 2019 when Congress amended ERISA to add a more streamlined fiduciary safe harbor covering the same activity.”

Effective Date: The final rule is effective September 2, 2025, unless significant adverse comments are received by July 31, 2025.

The Final Rule is available here:

https://www.federalregister.gov/documents/2025/07/01/2025-11615/selection-of-annuity-providers- safe-harbor-for-individual-account-plans

CANADA

The Canadian Security Administrators 2025 to 2028 Business Plan

The Canadian Security Administrators (CSA) has published its 2025 to 2028 business plan. The plan represents the collective effort by the CSA to set out, in a clear and comprehensive manner, the priorities the CSA have committed to pursue over the next three years.

The CSA’s Business Plan is available here:

https://www.securities-administrators.ca/wp-content/uploads/2025/06/CSA_BusPlan_Jun23_Eng.pdf#page=4