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On September 4, 2025, the Office of Information and Regulatory Affairs revealed the semi-annual “Unified Agenda of Regulatory and Deregulatory Actions” of the varied federal businesses. The Unified Agenda contains the SEC’s Spring 2025 Current Agenda containing the next objects from the Division of Investment Management, in addition to the SEC’s present timing estimates. From different SEC Divisions, the Current Agenda additionally comprises a number of crypto-related rulemakings, that are reproduced individually beneath. In many instances, the scope and substance of the rulemakings are ambiguous however the outline supplied.
|
Rulemaking |
Status & Timing |
Description |
|
Amendments to Form N-PORT |
Proposed Rule Stage Apr. 1, 2026 |
The Division of Investment Management (the “Division”) is contemplating recommending that the SEC suggest amendments to Form N-PORT to handle recognized disclosure burdens. |
|
Amendments to Rule 17a-7 Under the Investment Company Act |
Proposed Rule Stage Apr. 1, 2026 |
The Division is contemplating recommending that the SEC suggest amendments to Rule 17a-7 beneath the 1940 Act to modernize the circumstances for, and broaden the provision of, the exemption from Section 17(a), permitting sure buy or sale transactions between an funding firm and sure affiliated individuals. |
|
Amendments to the Custody Rules |
Proposed Rule Stage Apr. 1, 2026 |
The Division is contemplating recommending that the SEC suggest amendments to present guidelines and/or suggest new guidelines beneath the Investment Advisers Act and the 1940 Act to enhance and modernize the rules across the custody of advisory shopper and fund belongings, together with to handle in every case crypto belongings. |
|
Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers |
Final Rule Stage Apr. 1, 2026 Rule proposal described in a 2024 Ropes & Gray Alert |
The Division is contemplating recommending that the SEC, collectively with FinCEN, difficulty a last rule with regard to sure funding advisers that requires these funding advisers to implement cheap procedures to confirm the identities of their prospects. |
|
Crypto-Related Rulemaking |
Status & Timing |
Description |
|
Crypto Assets |
Proposed Rule Stage Apr. 1, 2026 |
The Division of Corporation Finance is contemplating recommending that the SEC suggest guidelines regarding the supply and sale of crypto belongings, doubtlessly to incorporate sure exemptions and secure harbors, to assist make clear the regulatory framework for crypto belongings and supply higher certainty to the market. |
|
Transfer Agents |
Proposed Rule Stage Apr. 1, 2026 |
The Division of Trading and Markets is contemplating recommending that the SEC suggest updates and refinements to modernize the present regulatory regime for switch brokers, together with guidelines regarding crypto belongings and the usage of distributed ledger expertise by switch brokers. |
|
Crypto Market Structure Amendments |
Proposed Rule Stage Apr. 1, 2026 |
The Division of Trading and Markets is contemplating recommending that the SEC amend Exchange Act Rules to account for the buying and selling of crypto belongings on ATSs and nationwide securities exchanges. |
Observations
As described in a Ropes & Gray Alert, in June, the SEC issued a discover formally withdrawing sure proposed rulemakings issued in 2022 and 2023 beneath the prior administration. In a statement accompanying the discharge of the Current Agenda, Chairman Atkins explicitly famous that “[i]mportantly, the agenda reflects our withdrawal of a host of items from the last Administration that do not align with the goal that regulation should be smart, effective, and appropriately tailored within the confines of our statutory authority.”
We anticipate that the SEC beneath Chairman Atkins will proceed to have a broad deregulatory orientation and, for the foreseeable future, will embody crypto-related rulemakings.
Each of the rulemakings signifies that the SEC plans its subsequent motion to happen by April 1, 2026. In some cases, that date is more likely to slip.
* * *
If you wish to be taught extra in regards to the points on this Alert, please contact your normal Ropes & Gray legal professional contacts.
This web page was created programmatically, to learn the article in its unique location you possibly can go to the hyperlink bellow:
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