The Unprecedented Incidence of Recent Rulemakings by the SEC

On July 15, 2022, the Committee released its first in a series of visual diagrams designed to track the unprecedented scale and complexity of recent rulemaking activity by the U.S. Securities & Exchange Commission (the “SEC”).   The Committee’s “Rulemaking Incidence Diagram” depicts proposed and final SEC rulemaking actions taken under SEC Chairman Gary Gensler, […]

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Committee Submits Comment Letter on the SEC’s Proposal on Climate Disclosure

On June 16, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule to require public companies to provide specified climate-related information in their registration statements and annual reports (the “Proposed Rule”). The Committee agrees with the Proposed Rule that it is important to “provide consistent, […]

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Committee Submits Comment Letter on the SEC’s Proposal on SPACs

On June 13, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on special purpose acquisition companies (“SPACs”), shell companies, and projections (the “Proposed Rule”). As set forth throughout the letter, the Committee’s review of empirical data on SPACs and de-SPACs finds that SPACs play […]

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Committee Submits Comment Letter on the Fed’s CBDC Consultation Paper

On May 20, 2022, the Committee submitted a comment letter to the Federal Reserve Board (the “Fed”) concerning its recent consultation paper, “Money and Payments: The U.S. Dollar in the Age of Digital Transformation,” which invites public discussion of the creation of a central bank digital currency (a “CBDC”). The Committee finds that the principal […]

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Committee Hosts Virtual Roundtable on IPOs and the Rise of SPACs

On April 27, 2022, the Committee hosted a Virtual Roundtable on “The Future of Going Public and Expanding Investor Opportunities: A Comparative Discussion on IPOs and the Rise of SPACs.” The roundtable vegan with Keynote Remarks from Commissioner Caroline Crenshaw of the U.S. Securities & Exchange Commission, followed by a panel discussion among subject matter […]

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Committee Submits Comment Letter on the SEC’s Private Funds Proposal

On April 25, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on private fund advisers (the “Proposed Rule”). The Proposed Rule includes a series of new rules and amendments under the Investment Advisers Act of 1940, as amended, applicable to investment advisers to private […]

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Committee Submits Comment Letter on the SEC’s Money Market Fund Proposal

On April 11, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on money market fund reforms. The Proposed Rule would make extensive changes to the rules governing money market funds (“MMFs”) under the Investment Company Act of 1940 (the “Act”), including by: (i) increasing […]

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Committee Submits Comment Letter on the SEC’s Security-based Swap Proposal

On March 21, 2022, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on the reporting of large security-based swap positions. The Committee’s letter proceeds in three parts. First, we describe the Proposed Rule’s reporting requirements, including a description of the credit default swaps and total […]

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Committee Submits Comment Letter on the SEC’s Securities Lending Proposal

On January 6, 2021, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding its proposed rule on the reporting of securities loans. If adopted, the proposed rule would (i) require the reporting of certain terms of securities lending transactions to designated registered national securities associations (“RNSAs”), and (ii) require […]

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Assessing The Future of U.S. Listings By Chinese Companies: A Call For Structured Dialogue

The Committee on Capital Markets Regulation (the “Committee”) is concerned with the potential impact on U.S. capital markets from recent policy developments in China and the United States indicating that Chinese companies may halt future listings on U.S. stock exchanges and that Chinese companies presently listed on U.S. stock exchanges may be delisted or will […]

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