On April 7, 2026, the SEC announced its enforcement results for fiscal year 2025. In 2025, 456 enforcement actions were filed. This included 303 standalone actions and 69 “follow-on” administrative proceedings seeking to bar or suspend individuals. You can read more about these results and the Commission’s strategy to refocus enforcement resources to address situations that harm investors, including fraud and the persons who perpetrate fraud.
As always, your thoughts and comments are welcome!
At “The SEC Speaks in 2026,” a conference presented by PLI in cooperation with the U.S. Securities and Exchange Commission, members of CorpFin announced that the comment letter posting process is about five months behind. Thus, information about comment letter volume and frequent comment areas will likely not be complete until the posting process is up to date. The staff did not provide an estimate of how long this would take.
As always, your thoughts and comments are welcome!
P.S., PLI provides a complimentary non-accredited live stream of The SEC Speaks, which you can find here.
Over the years we have blogged about the valuable guidance provided by CorpFin’s Compliance and Disclosure Interpretations (C&DIs). We have even lightheartedly referred to them as the CorpFin “candy” dish.
CorpFin has renamed this section of their guidance as Corporation Finance Interpretations, a shorter and perhaps broader name. There is still a consolidated, word searchable version of the interpretations. And we are taking suggestions for fun ways to build a nickname for the now named “CFIs.”
As always, your thoughts and comments are welcome!
The Holding Foreign Insiders Accountable Act requires directors and officers of foreign private issuers to file Section 16 reports to disclose their share ownership and transactions. This reporting requirement is effective as of March 18, 2026. On February 27, 2026, the SEC adopted Final Rules to implement this requirement. You can read more and find links to the Final Rules in this Press Release.
On March 9, 2026, CorpFin issued responses to a number of frequently asked questions (FAQs) about this new requirement. The FAQs address issues including the requirement that all reports must be filed on EDGAR and various deadline details.
As a reminder, it is appropriate to obtain EDGAR IDs for all affected persons well in advance of the March 18, 2026, filing effective date.
As always, your thoughts and comments are welcome!
As we discussed in this blog post, on August 13, 2025, the SEC published a new webpage that provides a wealth of information about capital market transactions, participants, activity and investors. As an example, included in the data visualizations is this graph about IPOs:
Underlying the graph is a tabular presentation that further breaks down the underlying data. The image below is a portion of this table:
As always, your thoughts and comments are welcome!
With SEC Chairman Paul Atkins’ remarks that it is “a new day at the SEC,” reporting companies and their advisors have been waiting to see exactly what this new day will entail. Chair Atkins has delivered numerous speeches about his priorities, most recently in this “Testimony Before the U.S. Senate Committee on Banking, Housing, and Urban Affairs” on February 12, 2026, and his “Remarks at the Texas A&M School of Corporate Law Symposium” on February 17, 2026.
On February 13, 2026, CorpFin Division Director James Moloney published a Statement titled “Coming Attractions From the Division of Corporation Finance” to shed more light on the Division’s priorities. His Statement addresses areas including crypto assets, Regulation S-K, semiannual reporting, FPI issues, updating staff guidance, the disclosure review process, and shareholder proposals. Clearly, these new days will be busy days for both the Commission and reporting companies!
As always, your thoughts and comments are welcome!
On January 23, 2026, continuing its process of updating C&DIs, CorpFin announced three additional sets of revisions and withdrawals. This first announcement addresses a number of C&DIs related to Securities Act issues, including delayed or continuous offerings and abandoned offerings. A number of proxy and tender offer related issues are addressed in this second announcement. CorpFin’s third announcement addresses executive compensation disclosures in a spin-off transaction setting.
As always, your thoughts and comments are welcome.
On January 13, 2026, SEC Chairman Paul S. Atkins issued a Statement titled “Statement on Reforming Regulation S-K.” In his Statement Chairman Atkins notes:
“Over the past forty-plus years, that repository (Regulation S-K) has grown from the size of a gym locker to the size of an artificial-intelligence data center. Today, the disclosure that companies provide in response to the myriad requirements of Regulation S-K does not always reflect information that a reasonable investor would consider important in making an investment or voting decision.”
Chairman Atkins has instructed the Division of Corporation Finance to conduct a comprehensive review of the disclosure requirements in Regulation S-K. The roundtable addressing executive compensation disclosure was a first step in this process. The staff is now moving its focus to other Regulation S-K disclosure requirements and comments are requested by April 13, 2026.
The Statement includes information about how to submit comments electronically or in writing.
As always, your thoughts and comments are welcome.
On December 5, 2025, CorpFin announced the latest update to its Financial Reporting Manual. The update addresses the SEC’s 2024 Final Rule for SPAC transactions. You can find a summary of the update on the FRM section of CorpFin’s webpage which also includes a link to the complete Financial Reporting Manual.
On December 2, 2025, SEC Chairman Paul S. Atkins delivered a speech at the New York Stock Exchange titled “Revitalizing America’s Markets at 250.” In his speech he discusses the history of our country and capital markets, addressees the impact of disclosure regulation, and enumerates possible disclosure reforms.
In one section of his remarks Chairman Atkins states:
“Over the years, and particularly over the past two decades, special interest groups, politicians, and—at times—the SEC itself have weaponized the disclosure regime that Congress created for our marketplace, in an effort to advance social and political agendas that stray far from the SEC’s mission of facilitating capital formation; protecting investors; and ensuring fair, orderly, and efficient markets.”
He also states:
“One of my priorities as Chairman is to reform the SEC’s disclosure rules with two goals in mind. First, the SEC must root its disclosure requirements in the concept of financial materiality. Second, these requirements must scale with a company’s size and maturity.”
He then outlines areas for possible reform, including simplifying executive compensation disclosures, scaling disclosure rules based on company size, and expanding the IPO on-ramp.
As always, your thoughts and comments are welcome!