Publications

On December 9, the California Air Resources Board (“CARB”) published proposed regulations to implement SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Act) and a staff report outlining CARB’s rationale for the regulations, and issued a notice of public hearing to consider approving for adoption the regulations on February 26, 2026. The proposed regulations are expected to be published by the California Office of Administrative Law on...

Introduction The Federal Communications Commission (the “Commission”) has proposed rules to completely overhaul its satellite and earth station licensing process by creating a “licensing assembly line” that is more efficient and predictable than current licensing procedures. The Notice of Proposed Rulemaking (“NPRM”) was published on December 5, 2025, with comments due on January 20, 2026 and reply comments due on February 18, 2026. The proposed rules are a response to the recent surge in...

On December 5, 2025, the Securities and Exchange Commission (the “SEC”) announced its consent to the termination of the remaining undertakings under the Global Research Analyst Settlement. Originally entered into in 2003 and 2004, the settlement imposed specific conduct and disclosure obligations on twelve major investment banks to address conflicts of interest between equity research analysts and investment banking personnel. The SEC has now agreed, subject to court approval, to rescind the...

November was a quiet month at the FTC, as the government was shut down for the first half of the month. However, the FTC began the month with an announcement from Chair Ferguson. While expressing the view that the agency’s focus should be on law enforcement rather than rule-making, the Chair indicated that he initiated the rule-making process to address unfair or deceptive fees in rental housing, a move that underscores the agency’s continued efforts to combat hidden fees. Class action activity...

The SEC Division of Examinations released its 2026 Examination Priorities, providing a first look into the Division’s stated focus areas for the new fiscal year.[1] The 2026 priorities are the first annual examination priorities published since SEC Chairman Paul Atkins began his tenure in April. The priorities include many long-standing, core SEC examination topics. However, consistent with the Division’s stated goal that the publication of its annual priorities “encourage[s] firms to direct...

On December 1, the California Air Resources Board (“CARB”) issued an Enforcement Advisory stating that it will not enforce California Health & Safety Code § 38533 against covered entities for failing to post and submit their Climate-Related Financial Risk Report under Senate Bill 261 (the Climate-related Financial Risk Act) by the reporting deadline of January 1, 2026. This action comes in the wake of an order by the U.S. Court of Appeals for the Ninth Circuit granting the plaintiffs a...

November 2025 witnessed increased industry attention for the European Union’s (EU) ongoing efforts to reform the regulatory frameworks applicable to securitisations. Further to our recent memo on three recent regulatory developments relating to the EU/UK securitisation markets, this memorandum sets out key takeaways from the Joint Statement: Investors’ Views on the Securitisation Review, published jointly by the Association for Financial Markets in Europe, Alternative Investment Management...

On 20 November 2025, the European Commission published its final proposals to overhaul the EU Sustainable Finance Disclosure Regulation (SFDR). The proposals present a radical departure from the original SFDR regime and move from a disclosure-based approach to a regime that establishes distinct investment categories with minimum sustainability standards that must be met by financial products making certain sustainability-related claims. The proposals follow on from an unofficial leak of an...

Recent EU and UK regulatory initiatives signal a renewed push to strengthen and scale the EU and UK securitisation markets, with three developments in particular highlighting how policymakers aim to broaden the investor base, refine prudential frameworks and mobilise long-term capital—especially from insurers. 1. ECON Committee hearing to assess the securitisation package amending the European Securitisation Regulation[1] (EUSR) and the Capital Requirements Regulation[2] (CRR) (13 October...

On November 18, 2025, the Federal Reserve released a Statement of Supervisory Operating Principles that sets out changes to how Federal Reserve examiners should supervise banking organizations. The Statement translates Vice Chair for Supervision Michelle Bowman’s stated priorities into concrete operating expectations for supervisory staff at the Federal Reserve Board and Federal Reserve Banks. The Statement follows an August 6, 2025, internal communication to Federal Reserve supervisory staff...

On November 17, 2025, the SEC’s Division of Corporation Finance announced that, during the 2025–2026 proxy season, due to resource constraints following the government shutdown and the breadth of existing guidance issued by the staff, the SEC staff will not respond to no-action requests or express views on companies’ intended reliance on Rule 14a-8 for exclusion of shareholder proposals in their proxy materials, except for requests related to state-law based exclusions under Rule...