BRAEDEN ANDERSON
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We provide authoritative analysis on securities and commodities regulation, SEC and FINRA enforcement, and legal developments affecting crypto, digital assets, fintech, and financial services, authored by Braeden Anderson.
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SEC Investor Advocate Outlines FY2026 Objectives: Focus on Retail Protection, Disclosure Efficacy, and Private Market Risks
On June 25, 2025, the Securities and Exchange Commission’s Office of the Investor Advocate submitted its annual Report to Congress, outlining the Office’s key policy objectives and areas of focus for Fiscal Year 2026. As retail participation in the markets continues to rise, the Investor Advocate’s priorities reflect a broader regulatory shift toward more data-driven investor protection efforts, disclosure modernization, and a closer examination of opaque market structures—including risks tied to private market exposure in retirement accounts and China-based issuers operating through variable interest entities (VIEs).
SEC Extends Compliance Date for Daily Reserve Computation Requirements Under Rule 15c3-3
On June 25, 2025, the Securities and Exchange Commission announced an extension of the compliance deadline for broker-dealers subject to its December 2024 amendments to Rule 15c3-3—the Customer Protection Rule. The amendments require certain broker-dealers to compute reserve requirements daily rather than weekly. The new compliance deadline has been extended from December 31, 2025, to June 30, 2026, providing firms with six additional months to complete the transition.
SEC Releases Data on Broker-Dealers, M&A Activity, and Business Development Companies
On June 26, 2025, the SEC’s Division of Economic and Risk Analysis (DERA) published three detailed reports providing updated data and analysis on broker-dealers, mergers and acquisitions (M&A), and business development companies (BDCs). These reports are part of the agency’s ongoing effort to enhance transparency and provide market participants with relevant data to support regulatory and commercial decision-making.
Regulation A and the Role of Finders: A Fresh Look at an Old Dilemma
The SEC’s Small Business Capital Formation Advisory Committee will convene on July 22, 2025, to revisit two of the most important—yet perennially underdeveloped—components of the U.S. private capital markets: Regulation A and the regulatory treatment of “finders.” Both topics go to the heart of one of the SEC’s toughest policy challenges: how to responsibly expand capital access for small and emerging businesses without sacrificing investor protection.
New Frontiers, Old Rules: SEC Staff Outlines Disclosure Expectations for Crypto Asset ETPs
On July 1, 2025, the SEC’s Division of Corporation Finance issued a comprehensive staff statement clarifying its views on disclosure obligations under the federal securities laws for issuers of crypto asset exchange-traded products (ETPs). While the products themselves represent novel financial structures—trust-based vehicles holding spot crypto or derivatives—the statement emphasizes continuity in legal obligations: crypto ETP issuers must adhere to well-established disclosure requirements under the Securities Act of 1933 and the Securities Exchange Act of 1934.