On June 12, 2025 the Securities and Exchange Commission (“SEC”) formally withdrew fourteen outstanding rule proposals issued by the prior administration. Although most observers doubted that the current Commission would adopt these proposals, the SEC’s action confirms that any future rulemaking on these topics must start anew with a new proposal and a fresh opportunity

John Mahon
John Mahon is a partner in the Registered Funds group and a member of the Investment Management practice. John has nearly 20 years of experience working with asset management clients in structuring, launching and managing regulated fund products and other permanent capital vehicles.
He represents private equity firms, credit managers and other financial sector participants in a wide range of fund formation, capital markets and securities law matters, including both public and private offerings of business development companies (BDCs) and other alternative vehicles, such as registered closed-end funds and interval funds.
John also has extensive experience in advising asset managers on the unique regulatory complexities involved in launching and managing registered funds and BDCs, including as part of larger platforms, and has sought and obtained SEC exemptive relief on behalf of numerous clients. He has been involved with more than 100 debt and equity offerings, including over 20 initial public offerings (IPOs), reflecting an aggregate of over $10 billion in total proceeds.
John’s work in securities law and mergers and acquisitions includes providing guidance to many New York Stock Exchange (NYSE) and Nasdaq-listed companies in connection with ongoing corporate governance and SEC reporting and compliance matters. He has routinely handled issues involving tender offers, proxy solicitations, going-private transactions, and beneficial ownership reporting obligations.
John previously worked in the U.S. Securities and Exchange Commission’s Division of Corporation Finance, where he earned the SEC Capital Markets Award.
He is a prominent and engaged member of the investment management community. He has spoken and written on topics ranging from SEC regulations and disclosure obligations to public and private capital raising structures, 1940 Act regulated funds and M&A issues.
John has served as an adjunct professor at the George Washington University Law School since 2009, and at the Georgetown University Law Center since 2023. He also formerly served as the chair of the Corporate Finance Committee of the Corporation, Finance and Securities Law Section of the District of Columbia Bar.
SEC Approves Exchange Listing Applications for Spot Bitcoin ETPs
On January 10, 2024, the Securities and Exchange Commission (“SEC”) issued an order approving the applications of 11 different spot Bitcoin exchange‑traded products (the “Approved ETPs”) to each list and trade their shares on a national securities exchange.[1] As a result, each Approved ETP is expected to commence trading on either the NYSE Arca…
Effect of the New NYSE and Nasdaq Clawback Listing Standards on Registered Funds and BDCs
Beginning on December 1, 2023, companies listed on the New York Stock Exchange (“NYSE”) and the Nasdaq Stock Market (“Nasdaq”) will need to adopt and comply with policies providing for the recovery, or “clawback”, of erroneously awarded incentive-based executive compensation, as required by Rule 10D-1 under the Securities Exchange Act of 1934 (“Rule 10D-1”).[1]…
SEC Staff Issues Bulletin on the Care Obligations of Advisers and Broker-Dealers to Retail Investors
On April 20, 2023, the staff of the Securities and Exchange Commission (the “SEC”) published an FAQ‑style bulletin[1] that provides guidance on the care obligations of broker‑dealers and investment advisers in providing investment advice and recommendations to retail investors. The bulletin emphasizes the importance of complying with the Care Obligation of Regulation Best Interest (“Reg BI”) for broker‑dealers and the duty of care enforced under the Investment Advisers Act of 1940, as amended (the “IA fiduciary standard”) for investment advisers (together, the “care obligations”). The care obligations are drawn from key fiduciary principles, including an obligation to act in the retail investor’s best interest and not to place the fiduciary’s interests ahead of the investor’s interest.