Paul Atkins

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The SEC has not yet released an official report of SEC Enforcement activity for Fiscal Year (FY) 2026, which ended September 30, 2026, but several other independent sources have released their own analyses. The numbers reflected in the independent sources’ report vary, but they are directionally consistent – they all show significantly reduced SEC enforcement activity in FY 2026, the agency’s first full year under current Chair Paul Atkins. As discussed below, reduced enforcement numbers may be interpreted in varying ways, but the lower FY2026 enforcement numbers do have important implications.

Continue Reading Reduced SEC Enforcement Activity in the 2026 Fiscal Year

As Sarah Abrams noted in a post on this site last September, President Trump, in a social media post, proposed eliminating quarterly report for public companies. On May 5, 2026, the SEC acted on the President’s suggestion and proposed a rule that would provide companies currently subject to the agency’s quarterly reporting requirements with the option to instead file interim reports semiannually. It seems likely that optional semiannual reporting will soon be put into effect. The question is whether this is a good idea or will produce the intended benefits, as discussed below.

Continue Reading SEC Proposes Allowing Optional Semiannual Reporting

It is no secret that SEC Chair Paul Atkins has ideas about how U.S. securities laws could be reformed to “revitalize” America’s capital markets. Among other things, late last year Atkins proposed a number of revisions to the current U.S. public company disclosure regime. Now, in a speech earlier this week, Atkins floated several additional proposed reforms, among other things referring to the possibility of loser-pays bylaws for shareholder suits and of a “safe harbor” for public company disclosures concerning widely publicized events. As discussed below, Atkins’s recent ideas have a long and relevant history. The text of Atkins’s February 17, 2026, speech can be found here.

Continue Reading SEC Chair Atkins Proposed Further Securities Litigation and Disclosure Reform

There is no doubt that the SEC under current Chair Paul Atkins has taken a different enforcement approach than under the prior administration. The statistics (at least those through the end of the last fiscal year) show a notable decrease in the number of SEC enforcement actions under the Trump administration.  As questions arise about the current administration’s enforcement approach, including whether the agency’s approach might embolden would-be wrongdoers, one particular question has been with respect to the Director of the agency’s Enforcement Division. Observers have asked whether the division director, Margaret “Meg” Ryan, who was nominated to her position last August, is deliberately leading the division in a hands-off approach.

Continue Reading SEC Enforcement Division Director Assures of Continued Vigilance

It is no secret that the SEC under the Trump Administration is taking a very different approach to cryptocurrency than the agency did under the Biden Administration. Indeed, a detailed December 2025 New York Times article (here) made it clear – if there were any doubt — that the administration’s more restrained approach to crypto starts at the very top. But what does the more restrained crypto approach mean in practical terms? A January 22, 2026, report from Cornerstone Research, which can be found here, spells out in detail what it means, both in terms of reduced numbers of crypto-related enforcement actions and in diminished crypto-related recoveries.

Continue Reading SEC: Less Crypto Enforcement, Lower Crypto Recoveries
Sarah Abrams

Among one of many changes afoot at the SEC under its current Chair Paul Atkins is Atkins’s proposal calling for the agency to reconsider its rule allowing shareholders to include non-binding shareholder resolutions in corporate proxy materials. In the following guest post, Sarah Abrams, Head of Claims Baleen Specialty, a division of Bowhead Specialty, takes a look at Atkins’s proposal concerning shareholder resolutions and considers the potential impact of a rule change on D&O liability. I would like to thank Sarah for allowing me to publish her article on this site.

Continue Reading Guest Post: Is the SEC Signaling the End of ESG Shareholder Proposals?

As noted in @Sarah Abrams’s recent guest post (here), President Trump last week proposed in a social media post changing the periodic reporting requirements for public companies from quarterly to semi-annual. Based on a separate interview of SEC Chair Paul Atkins published last week, it appears that the agency is prepared to move forward quickly with this proposal. We can expect to hear a lot of debate in the coming days about whether the proposed changed reporting requirements are a good idea. The Wall Street Journal had an interesting article on Saturday about the proposed change, clearly coming down on the side that the proposed change is not a good idea. As discussed below, the article also had some interesting information and comparisons that will add to the discussion about the proposal.

Continue Reading All the Problems with Eliminating Quarterly Reporting

In my recent roundup of the top current stories in the world of D&O, I noted the increasing importance of geopolitical issues as a source of D&O claims risk. Among the factors supporting this trend is the rising relevance of cross-border enforcement initiatives, which in many instances had led to D&O claims. In the latest sign of the importance of cross-border enforcement issues, the SEC has announced the formation of a cross-border task force to “identify and combat cross-border fraud harming U.S. investors.” The SEC’s September 5, 2025, press release about the task force can be found here.  A September 10, 2025, post on TheCorporateCounsel.net blog about the new task force’s formation can be found here.

Continue Reading SEC Forms Task Force to Combat Cross-Border Fraud
Sarah Abrams

We are now well into the new Trump administration. The President’s nominee to head the SEC, Paul Atkins, has now been sworn in. At the same time, the SEC is also dealing with the fallout from the U.S. Supreme Court’s decision last term in the Jarkesy case. In the following guest post, Sarah Abrams takes a look at what all this could mean for the SEC. Sarah is Head of Claims, Baleen Specialty, a division of Bowhead Specialty. I would like to thank Sarah for allowing me to publish her article on my site. I welcome guest post submissions from responsible authors on topics of interest to this site’s readers. Please contact me directly if you would like to submit a guest post. Here is Sarah’s article.

Continue Reading The Post-Jarkesy, Atkins SEC

On April 21, 2025, Paul Atkins, President Trump’s nominee, was officially sworn in as the 34th Chair of the Securities and Exchange Commission. Atkins, who previously served as an SEC Commissioner from 2002 to 2008 during the George W. Bush administration, brings extensive prior SEC experience to his new post. In many ways that are already in evidence at the SEC in the early days of the Trump administration, the new leadership is likely to result in many significant changes in direction at the agency.

Continue Reading Paul Atkins Chair Sworn In as SEC Chair