Practical, Experience-Based Insights on Financial Regulatory Developments
Welcome to the FinReg Monthly Update, a regular bulletin highlighting the latest developments in UK, EU and U.S. financial services regulation.
Key Developments in April 2026:
29 April 2026 – BoE/PRA: The Bank of England and the PRA have published finalised statements of policy outlining their approach…
On 4 May 2026, the European Parliament’s Economic and Monetary Affairs Committee (“ECON”) published its draft report (the “Draft Report”) on the European Commission’s proposed overhaul of the Sustainable Finance Disclosure Regulation (SFDR 2.0). The Draft Report includes a draft European Parliament legislative resolution setting out proposed amendments to the European…
On May 5, 2026, the SEC proposed to permit public companies to file semiannual reports instead of quarterly reports. If adopted, companies subject to Exchange Act Section 13(a) or 15(d) that currently file quarterly reports on Form 10-Q could elect to file one semiannual report on new Form 10-S and one annual report on Form…
The European Union’s ESG Ratings Regulation (the “Regulation”) will apply from 2 July 2026 and establishes a regulatory framework governing the provision of ESG ratings within the European Union. It introduces requirements relating to authorisation, governance, conflicts of interest and transparency, including public disclosures on rating methodologies (for example, via website disclosures).
Although primarily directed…
On April 16, 2026, the SEC’s Division of Corporation Finance issued an exemptive order permitting certain tender offers for equity securities to remain open for as few as 10 business days rather than the current 20-business-day minimum under Exchange Act Rules 13e-4(f)(1)(i) and 14e-1(a). The Division said the relief is intended to address market inefficiencies…
The SEC’s Division of Trading & Markets today issued a conditional no-action position that it would not object if compliant “user interfaces” designed to facilitate the execution of crypto securities transactions operate without registering as broker-dealers. In plain English, the staff’s position applies to interfaces operating in a neutral fashion by providing mechanics to facilitate…
Introduction
On 25 March 2026, the UK Financial Conduct Authority (FCA) published Consultation Paper 26/10 ‘Simplifying the Pensions & Investment Advice Rules’.
As the name suggests, the Consultation Paper seeks stakeholder feedback on a proposed consolidation and simplification of the current rules on pensions and investment advice, which are found in…
There has been movement forward on the Clarity Act, and the SEC and CFTC have anticipated its passage by pre-emptively completing a “memorandum of understanding” that would be required by the Act, and by beginning the “rulemaking” process with a joint interpretive release distinguishing between “investment contract assets” regulated by the SEC and “digital commodities”…
On March 17, 2026, the Securities and Exchange Commission (the “SEC”) issued interpretive guidance addressing how existing federal securities laws apply to certain types of crypto assets and certain transactions involving crypto assets (the “Interpretation”). The Commodity Futures Trading Commission (the “CFTC”) joined the guidance and confirmed its staff would administer the Commodity Exchange Act…
In a significant development for antitrust practitioners and dealmakers, the U.S. Court of Appeals for the Fifth Circuit denied the Federal Trade Commission’s motion for a stay pending appeal in the long standing litigation over the agency’s revised Hart-Scott-Rodino (HSR) filing requirements. The immediate consequence is a reversion to the pre-February 10, 2025 HSR filing…
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