Thoughts
SEC Issues No-Action for Automatic Voting by Retail Shareholders
This is massive, yet not many folks are talking about it. In September 2025, the Securities and Exchange Commission quietly approved automatic voting for our retail investors through a “no-action” letter. The SEC’s Division of Corporation Finance told ExxonMobil that its staff would not recommend enforcement if the company launched a program allowing retail shareholders to cast standing voting instructions. Meaning: retail shareholders can now automatically set their voting preferences. It may sound boring or too technical to matter, but this decision could reshape how millions of individual investors take part in corporate governance across the U.S.
SEC No-Action Relief for State Trust Companies Custodying Digital Assets
The SEC is beginning to align its custody framework for digital assets with industry practice. The SEC’s Division of Investment Management has issued a no-action letter confirming that certain state-chartered trust companies may serve as qualified custodians for digital assets and related cash equivalents under the Investment Advisers Act and the Investment Company Act. This means that registered investment advisers and funds can now custody crypto assets with eligible state trust companies, entities the SEC staff is now willing to treat as “banks” for custody purposes.
SEC’s DoubleZero No-Action Letter: What It Means for Crypto Law
The SEC is increasingly pro-crypto now. On September 29 2025, the SEC’s Division of Corporation Finance issued no-action relief to the DoubleZero Foundation, clearing its planned token distributions from the registration requirements of Section 5 of the Securities Act and Section 12(g) of the Exchange Act. This puts DoubleZero alongside projects such as TurnKey Jet, Pocketful of Quarters, and IMVU, a small group that has received similar relief for token distributions with clear, functional use cases.