Author:Keller Albertson

1
United States: It’s Official-The SEC Issues a Revised Enforcement Manual for the First Time in Nearly a Decade
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United States: The Judge Speaks: The SEC’s New Enforcement Director Provides First Glimpse into Her Priorities
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United States: Saw This Coming: FINRA Proposes Rule Change to Permit Projected Performance
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Europe: UK FCA Plans to Streamline UK Sustainability Reporting
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Europe: UK Consultations on Reducing the Burden of the FCA Senior Managers Regime
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Europe: Fundamental Reform of UK Taxation of Carried Interest
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Europe: Central Bank of Ireland Updates its UCITS Q&A on Portfolio Transparency for ETFs
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United States: SEC Appears Poised to Bolster Competition on “Y’all Street”
9
Europe: UK’s FCA Intensifies Scrutiny on Private Markets Valuations
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Europe: UK’s FCA Seeks to Simplify Its Rules

United States: It’s Official-The SEC Issues a Revised Enforcement Manual for the First Time in Nearly a Decade

By: Thoreau Bartmann, Theodore Kornobis, and Neil Smith

Understanding the SEC’s Revised Enforcement Manual

Understanding the SEC’s enforcement approach is critical for practitioners and regulated entities alike. One of the few public documents describing how the Division of Enforcement conducts its business is the Enforcement Manual, which provides guidance to staff on conducting investigations, engaging with parties, and resolving matters—including the Wells process and cooperation credit.

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United States: The Judge Speaks: The SEC’s New Enforcement Director Provides First Glimpse into Her Priorities

By: Thoreau Bartmann, Lance Dial, Stephen Topetzes, and Meghan Flinn

Judge Margaret Ryan, the newly-appointed director of the Enforcement Division of the Securities and Exchange Commission (SEC) gave her first public remarks this week. Given the “new day” dawning at the SEC, many have been eager to hear her vison for the role of Enforcement at the SEC. Judge Ryan delivered!

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United States: Saw This Coming: FINRA Proposes Rule Change to Permit Projected Performance

By: Jessica D. Cohn, Lance C. Dial, and Derek N. Lacarrubba

Everyone wants to know what tomorrow will bring, and FINRA has proposed amendments to Rule 2210 (Proposed Amendments) that would give broker-dealers more flexibility to communicate exactly that – at least as it relates to projected performance and targeted returns. If adopted, the Proposed Amendments would more closely align FINRA Rule 2210 with the rule governing investment adviser marketing (the Marketing Rule).

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Europe: UK FCA Plans to Streamline UK Sustainability Reporting

By: Kai Zhang and Andrew Massey

Following a multi-firm review of sustainability reporting, the FCA has announced that it is considering how to streamline and enhance the UK’s sustainability reporting framework by simplifying disclosures, easing unnecessary compliance burdens, improving the decision-usefulness of reporting and promoting international alignment.

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Europe: UK Consultations on Reducing the Burden of the FCA Senior Managers Regime

By: Zainab Kuku, Philip Morgan, and Andrew Massey

As part of the UK government’s strategy to boost the competitiveness of the UK financial services sector and support growth, the overall burdens of the Senior Managers & Certification Regime (SMCR) are to be reduced “by 50%”.

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Europe: Fundamental Reform of UK Taxation of Carried Interest

By: Giles Bavister, Ayesha Gill, and Neil Woodgate

From 6 April 2026, carry will be redefined and taxed in the United Kingdom as deemed UK trade or business income where investment management services (as redefined) are performed in the UK. The relevant draft legislation was published by HMRC in July 2025.

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Europe: Central Bank of Ireland Updates its UCITS Q&A on Portfolio Transparency for ETFs

By: Lucy Deane, Hazel Doyle, and Nicola McCaffrey

In a move that will be welcomed by asset managers conducting ETF business in Ireland, or those who are hoping to move into the Irish ETF space, the Central Bank of Ireland has moved to allow for the establishment of semi-transparent ETFs by amending its requirements for portfolio transparency.

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United States: SEC Appears Poised to Bolster Competition on “Y’all Street”

By: Jessica Cohn and Caroline Roethlisberger

On 4 April 2025, the Securities and Exchange Commission (SEC) published Texas Stock Exchange’s (TXSE) Form 1 Application and Exhibits, indicating that the SEC intends to grant TXSE’s registration as a national securities exchange. The application provides new details about TXSE, including its proposed listing standards and requirements and the technology to be utilized. TXSE has previously announced that it expects to receive that necessary SEC approval and be listing companies and funds on its exchange by early 2026.

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Europe: UK’s FCA Intensifies Scrutiny on Private Markets Valuations

By: Daniel Greenaway and Flavio Picaro

The UK’s Financial Conduct Authority has published the findings of its multi-firm review of valuation processes for private market assets. This review follows the highlighting of vulnerabilities in private markets stemming, in part, from opaque valuations, in both the Bank of England’s June 2024 Financial Stability Report and IOSCO’s September 2023 report on emerging risks in private finance markets.

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Europe: UK’s FCA Seeks to Simplify Its Rules

By: Laura Price and Kai Zhang

Acknowledging “longstanding concerns from firms about the length and complexity of [its] rules and guidance”, the UK’s FCA published a call for input in July 2024. It invited firms to comment on whether some FCA rules may be unnecessary following introduction of the outcomes-based Consumer Duty. It has now outlined its proposed approach in a Feedback Statement, explaining that its aims are to achieve more flexibility, more predictability, and improved efficiency. The approach includes:

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