As previously reported in Proskauer’s client alert (available here), on May 19, 2026, the Securities and Exchange Commission (SEC) proposed significant amendments to its public company reporting framework to simplify the existing filer status regime and substantially expand eligibility for scaled disclosure accommodations. Consistent with SEC Chairman Paul Atkins’ plan to “Make IPOs Great
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SEC Proposes Significant Overhaul of Filer Status Framework
On May 19, 2026, the Securities and Exchange Commission (SEC) proposed significant amendments to the public company reporting framework that would simplify the current filer status regime and substantially expand the availability of scaled disclosure accommodations. The current framework requires companies to annually reevaluate their filer status (large accelerated filer, accelerated filer, non-accelerated filer) and…
Swaps or Sportsbooks? The CFTC’s Expanding Battle Over Prediction Markets
Prediction markets have recently emerged as a major focus of both federal and State regulators. With reported daily trading volumes exceeding $100 million ‑ and substantially more during major events such as the Super Bowl and federal elections ‑ these markets have drawn increasing scrutiny over concerns involving insider trading, market manipulation, and consumer protection.…
Proskauer Secures Unanimous Victory at the New York Court of Appeals on Behalf of Three Legal Services Organizations
In a unanimous decision, the New York Court of Appeals struck down regulations that would have created a new state-run system for parents to place their children with strangers. The Court held that the “Host Homes” program unlawfully strips away core protections for children and parents under New York State’s voluntary foster care system,…
SEC Proposes Transformative Offering Reform: Significant Implications for Operating Companies, Registered Closed-End Funds, BDCs, and Other Products
On May 19, 2026, the Securities and Exchange Commission (SEC) proposed a sweeping set of rule and form amendments intended to modernize and simplify the registered securities offering process for public companies, registered closed-end funds (RCEFs), business development companies (BDCs), and other products. The proposal, if adopted, would be the most significant update to the…
$103 Million “Thermonuclear” Age Discrimination Verdict Overturned In Los Angeles
In a welcome reminder that eye-popping punitive damage awards still face meaningful judicial scrutiny, a Los Angeles Superior Court judge has struck down an $83 million punitive damages award that was entered against Liberty Mutual in Slagel v. Liberty Mut. Ins. Co. However, the court left intact a $20 million award for emotional distress damages…
SEC Rescinds “No-Deny” Settlement Policy: What Changes?
The SEC has rescinded Rule 202.5(e), the no-admit/no-deny policy originally adopted in 1972 that prohibited settling defendants from publicly denying the allegations in an SEC complaint or administrative order. The SEC can still settle cases on a no-admissions basis, and can still seek admissions in particular cases, but settling parties will no longer be…
SEC Expected to Propose Trading in Tokenized, Phantom Public Company Common Stock
The SEC is reported to be planning to issue rule proposals creating a regulatory framework for trading of tokenized, digital securities of publicly-traded companies that are issued by third parties unaffiliated with the issuer. The tokens would be similar to “phantom stock,” representing digital representations of the securities, but would have no equity or voting…
Back in Business? The IRS Revives “Significant Issue” Rulings for Corporate Transactions
On May 5, 2026, the Internal Revenue Service (“IRS”) released Revenue Procedure 2026-21 (the “Rev. Proc.”), which reinstates a program under which taxpayers may request private letter rulings (“PLRs”) on “significant issues” arising in certain corporate transactions[1] without asking the IRS to rule on the entire integrated transaction.[2]
Although ruling opportunities remain limited…
2025 SEC Enforcement Results – Takeaways for Fund Managers
On April 7, 2026, the SEC’s Division of Enforcement announced its Enforcement Results for Fiscal Year 2025, several months later than usual. Overall enforcement numbers declined again, as expected, but FY 2025 was an unusual transition year. Significant filing activity occurred before the change in administration, and the new Commission used the release to…