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Articles by Wayne Aaron
Financial Markets and Funds Quick Take | Issue 52
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds.
The Return of Security Futures: What CME's Single Stock Futures Mean for Broker-Dealers and FCMs
For the better part of two decades, security futures in the United States have been less a living product than a regulatory artifact. The category was first conceived in the Shad-Johnson Accord between the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) in 1982 and was then given legal life by the Commodity Futures Modernization Act (CFMA) in 2000. Even so, security futures struggled, for many reasons, to find a foothold in US financial markets.
Financial Markets and Funds Quick Take | Issue 52
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds. To read more issues of Katten's Financial Markets and Funds Quick Take, please click here.
SEC Proposes Regulation E-Delivery- A New Default to Electronic Delivery Under Federal Securities Laws
The US Securities and Exchange Commission (the “SEC” or the “Commission”) released its proposal for Regulation E-Delivery (“Reg E-Delivery”) on July 16, 2026, which would form the Commission’s primary framework for electronic delivery of regulatory information under the federal securities laws.[1] As noted in its accompanying fact sheet, the Commission’s central concern is that the current default of paper delivery unless, a recipient affirmatively elects otherwise, no longer reflects the...
The SEC is Through with the Trade-Through Rule
After a series of industry roundtables and clear messaging from Chairman Paul S.
Financial Markets and Funds Quick Take | Issue 50
May 27, 2026 Wayne Aaron, Adam Bolter, Cathleen Booth, James Brady, Christopher Collins, Daniel Davis, Michael Didiuk, Michael Diver, Jessica Gracik, Ryan Hansen, Ted Huffman, Lori Jacobs, Christian Kemnitz, Carl Kennedy, Alexander Kim, Matthew Kluchenek, Thomas Laurer, Susan Light, Michael Lohnes, Richard Marshall, Casey McClaren, Neil Robson, Zachary Schmitz, Christopher Shannon, Edward Tran, Alexa Warner, Ciara Watson, Brigitte Weaver, Peter Wilson, Lance Zinman Katten Muchin Rosenman LLP...
A Major Change in SEC Enforcement Settlements: SEC Rescinds ‘No-Deny’ Policy
On May 18, 2026, the Securities and Exchange Commission (SEC) announced that it had rescinded its longstanding “no-deny” (gag) settlement policy, codified in Rule 202.5(e) of its informal rules of procedure. For more than 50 years, the SEC would not settle an enforcement action involving a sanction unless the respondent agreed not to deny the Commission’s allegations publicly.
Financial Markets and Funds Quick Take | Issue 50
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds. To read more issues of Katten's Financial Markets and Funds Quick Take, please click here. By Wayne M.
Financial Markets and Funds Quick Take | Issue 49
April 29, 2026 Wayne Aaron, Adam Bolter, Cathleen Booth, James Brady, Kevin Broughel, Alan Brudner, Wendy Cohen, Daniel Davis, Michael Didiuk, Nicholas Gervasi, Jessica Gracik, Anita Hodea, Lori Jacobs, Christian Kemnitz, Carl Kennedy, Alexander Kim, Matthew Kluchenek, Nathaniel Lalone, Ben Levine, Zoe Lo, Michael Lohnes, Casey McClaren, Stephen Morris, Scott Resnik, Michael Rosensaft, Jonah Roth, Zachary Schmitz, Christopher Shannon, Alexa Warner, Peter Wilson, Lance Zinman Katten Muchin...
SEC Outlines Time-Limited Path Forward for Crypto User Interface Providers on Broker-Dealer Registration
The Securities and Exchange Commission’s (SEC or the Commission) Division of Trading and Markets yesterday released a Staff statement (the Statement) outlining conditions under which providers of certain crypto asset securities user interfaces may operate without registering as broker-dealers under Section 15(a) of the Securities Exchange Act of 1934, as amended (the Exchange Act).
Financial Markets and Funds Quick Take | Issue 49
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds. To read more issues of Katten's Financial Markets and Funds Quick Take, please click here.
SEC Outlines Time-Limited Path Forward For Crypto User Interface Providers On Broker-Dealer Registration
The Securities and Exchange Commission’s (SEC or the Commission) Division of Trading and Markets yesterday released a Staff statement (the Statement) outlining conditions under which providers of certain crypto asset securities user interfaces may operate without registering as broker-dealers under Section 15(a) of the Securities Exchange Act of 1934, as amended (the Exchange Act).
SEC Chairman Atkins Outlines Vision and Priorities at SIFMA Compliance and Legal 2026 Annual Conference
In a candid fireside chat at the 2026 SIFMA Compliance and Legal Annual Conference, Securities and Exchange Commission (SEC or Commission) Chairman Paul S. Atkins provided a comprehensive overview of his approach to leading the Commission, highlighting a robust agenda focused on modernization, regulatory clarity, and transformation in a rapidly evolving financial landscape.
Reimagining Securities Arbitration: FINRA Launches Broad Review of Arbitration Rules and Requests Comment on Modernization Initiative | JD Supra
Responding to concerns raised and longstanding debates over how the Financial Industry Regulatory Authority’s (FINRA) arbitration forum functions, on March 2, FINRA issued Regulatory Notice 26‑06, seeking public comment on modernization of its arbitration rules, guidance and processes, as part of its broader “FINRA Forward” rule modernization program.[1] The Notice signals that core features of FINRA arbitration, including forum selection, claim eligibility, dispositive motion practice,...
Financial Markets And Funds Quick Take | Issue 48
Wayne M. Aaron’s articles from Katten Muchin Rosenman LLP are most popular: with Senior Company Executives, HR and Finance and Tax Executives in Asia with readers working within the Accounting & Consultancy, Banking & Credit and Technology industries By Daniel Davis, Carl Kennedy, Eli Krasnow, Benjamin Levine, Alexa Warner The Commodity Futures Trading Commission (CFTC) made waves on March 12 with two pivotal releases intended to shape the regulatory framework for prediction markets.
SEC Issues Guidance On Tokenized Securities
On January 28, the Securities and Exchange Commission's (SEC) Divisions of Corporation Finance, Investment Management, and Trading and Markets jointly released a joint statement on tokenized securities (Staff Statement).1 The Staff Statement returns to a familiar theme in the digital asset space: changing how ownership is recorded does not change what is being sold.
SEC Issues Guidance on Tokenized Securities | JD Supra
On January 28, the Securities and Exchange Commission's (SEC) Divisions of Corporation Finance, Investment Management, and Trading and Markets jointly released a joint statement on tokenized securities (Staff Statement).1 The Staff Statement returns to a familiar theme in the digital asset space: changing how ownership is recorded does not change what is being sold.
SEC Staff Issues Helpful Guidance on Custodying Digital Asset Securities and Complying with the Customer Protection Rule
On Wednesday, December 17, the SEC’s Division of Trading and Markets (Division) issued a helpful statement (the Statement) to clarify its views on how a broker-dealer can meet its obligation pursuant to paragraph (b)(1) of Rule 15c3-3 of the Securities Exchange Act of 1934, as amended (the Customer Protection Rule), with respect to digital or crypto assets that are securities that a broker-dealer may carry for the accounts of its customers.
Financial Markets and Funds Quick Take | Issue 46
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds. To read more issues of Katten's Financial Markets and Funds Quick Take, please click here.
SEC Clears Path For Tokenized Securities
In a flurry of activity, the Securities and Exchange Commission (SEC) has taken decisive steps to integrate blockchain technology into traditional securities market infrastructure. First, in a media appearance, Chairman Paul Atkins publicly championed tokenization as the future of market modernization. Days later, the SEC's Division of Trading and Markets issued a no-action letter allowing the Depository Trust Company to launch a pilot program for tokenized securities.
Path for Tokenized Securities Cleared by SEC
In a flurry of activity, the Securities and Exchange Commission (SEC) has taken decisive steps to integrate blockchain technology into traditional securities market infrastructure. First, in a media appearance, Chairman Paul Atkins publicly championed tokenization as the future of market modernization. Days later, the SEC’s Division of Trading and Markets issued a no-action letter allowing the Depository Trust Company to launch a pilot program for tokenized securities.
SEC Staff Issues Helpful Guidance on Custodying Digital Asset Securities and Complying with the Customer Protection Rule | JD Supra
On Wednesday, December 17, the SEC’s Division of Trading and Markets (Division) issued a helpful statement (the Statement) to clarify its views on how a broker-dealer can meet its obligation pursuant to paragraph (b)(1) of Rule 15c3-3 of the Securities Exchange Act of 1934, as amended (the Customer Protection Rule), with respect to digital or crypto assets that are securities that a broker-dealer may carry for the accounts of its customers.
SEC Clears Path for Tokenized Securities
In a flurry of activity, the Securities and Exchange Commission (SEC) has taken decisive steps to integrate blockchain technology into traditional securities market infrastructure. First, in a media appearance, Chairman Paul Atkins publicly championed tokenization as the future of market modernization. Days later, the SEC’s Division of Trading and Markets issued a no-action letter allowing the Depository Trust Company to launch a pilot program for tokenized securities.
Pay Attention To Your Orphans
What should a broker-dealer do when a customer's contact information no longer works? The law imposes responsibilities on broker-dealers in such situations. We expect the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and State securities regulators to have heightened interest and increased scrutiny over "orphaned" accounts, which are those where the designated representative relationship has ended or the client has become unresponsive.
Pay Attention to Your Orphans | JD Supra
What should a broker-dealer do when a customer's contact information no longer works? The law imposes responsibilities on broker-dealers in such situations. We expect the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and State securities regulators to have heightened interest and increased scrutiny over "orphaned" accounts, which are those where the designated representative relationship has ended or the client has become unresponsive.
SEC Division of Examinations Releases Its 2026 Examination Priorities - A Return to Core Principles, with a Cooperative Tone | JD Supra
Delayed slightly by the recent government shutdown, the Division of Examinations (the Division) of the Securities and Exchange Commission (SEC) recently published its fiscal year 2026 examination priorities (the Priorities).1 The Priorities include specific examination areas relating to investment advisers, broker-dealers, self-regulatory organizations, investment companies and other financial market participants.
A Re-Set for Investment Management and Heavy Emphasis on Crypto Assets | JD Supra
The Securities and Exchange Commission (the SEC or the Commission) recently released its Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions (the Agenda). While the Agenda appears undersized at 23 items compared to the 30 items that populated former Chairman Gary Gensler’s Fall 2024 list, it nonetheless signals several potentially consequential rulemakings — and an equally important shift in regulatory philosophy — under newly installed Chairman Paul S. Atkins.
Financial Markets and Funds Quick Take | Issue 38 | JD Supra
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds. To read more issues of Katten's Financial Markets and Funds Quick Take, please click here.
SEC's Division Of Trading And Markets Issues New FAQ Guidance On Broker-Dealer Custody And Net Capital Treatment Of Cryptoassets
The Securities and Exchange Commission (SEC) has taken a significant step toward permitting broker-dealers to custody digital assets and toward accounting for such proprietary digital assets in a broker-dealer's net capital computation.
SEC’s Division of Trading and Markets Issues New FAQ Guidance on Broker-Dealer Custody and Net Capital Treatment of Cryptoassets | JD Supra
The Securities and Exchange Commission (SEC) has taken a significant step toward permitting broker-dealers to custody digital assets and toward accounting for such proprietary digital assets in a broker-dealer’s net capital computation.
Financial Markets and Funds Quick Take | Issue 38
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds. To read more issues of Katten's Financial Markets and Funds Quick Take, please click here.
Financial Markets And Funds Quick Take | Issue 37
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds. To read more issues of Katten's Financial Markets and Funds Quick Take, please click here.
Financial Markets and Funds Quick Take | Issue 37 | JD Supra
Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds. To read more issues of Katten's Financial Markets and Funds Quick Take, please click here.
Financial Markets and Funds Quick Take | Issue 37 | JD Supra
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The Political Consequences of Controversial Education Reform: Lessons from WisconsinS Act 10
81 Pages Posted: 15 Apr 2025 Last revised: 7 May 2025 There are 2 versions of this paper Keywords: Teacher Salaries, Collective Bargaining, Political Feasibility, Education Reform JEL Classification: I20, P46, P11, J31, J45 Suggested Citation: Suggested Citation Biasi, Barbara and Sandholtz, Wayne Aaron, The Political Consequences of Controversial Education Reform: Lessons from WisconsinS Act 10. IZA Discussion Paper No. 17836, Available at SSRN: https://ssrn.com/abstract=5217534
FINRA Proposes And Seeks Comment On Simplified Rules For Outside Business Activities And Private Securities Transactions
KM Katten Muchin Rosenman LLP More Katten is a firm of first choice for clients seeking sophisticated, high-value legal services globally. Our nationally and internationally recognized practices include corporate, financial markets and funds, insolvency and restructuring, intellectual property, litigation, real estate, structured finance and securitization, transactional tax planning, private credit and private wealth.
FINRA Proposes and Seeks Comment on Simplified Rules for Outside Business Activities and Private Securities Transactions | JD Supra
On Friday, March 14, in Regulatory Notice 25-05, the Financial Industry Regulatory Authority (FINRA) proposed a new rule to address when registered individuals engage in activities away from their member firms and when associated persons (which can be registered or unregistered individuals) engage in securities transactions away from their member firms.
FINRA Proposes and Seeks Comment on Simplified Rules for Outside Business Activities and Private Securities Transactions
Skip to main content March 17, 2025 Volume XV, Number 76 Legal Analysis. Expertly Written. Quickly Found.
FINRA Proposes and Seeks Comment on Simplified Rules for Outside Business Activities and Private Securities Transactions
On Friday, March 14, in Regulatory Notice 25-05, the Financial Industry Regulatory Authority (FINRA) proposed a new rule to address when registered individuals engage in activities away from their member firms and when associated persons (which can be registered or unregistered individuals) engage in securities transactions away from their member firms.
Privacy, Data and Cybersecurity Quick Clicks | Issue 26 | JD Supra
Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe. To read more issues of Katten's Privacy, Data and Cybersecurity Quick Clicks, please click here.
Privacy, Data and Cybersecurity Quick Clicks | Issue 26
Katten's Privacy, Data and Cybersecurity Quick Clicks is a monthly newsletter highlighting the latest news and legal developments involving privacy, data and cybersecurity issues across the globe. To read more issues of Katten's Privacy, Data and Cybersecurity Quick Clicks, please click here.
SEC Grants Further Relief From Including Personally Identifiable Information In CAT Reporting
On February 10, the Securities and Exchange Commission (SEC) granted relief exempting industry members from reporting a natural person's name, address, and year of birth to the Consolidated Audit Trail (CAT). Industry members must still report transformed social security numbers (SSNs) or individual taxpayer identification numbers (ITINs) for natural persons and, to the extent applicable, Larger Trader IDs (LTIDs) and Legal Entity Identifiers (LEIs).
SEC Grants Further Relief From Including Personally Identifiable Information in CAT Reporting | JD Supra
On February 10, the Securities and Exchange Commission (SEC) granted relief exempting industry members from reporting a natural person’s name, address, and year of birth to the Consolidated Audit Trail (CAT). Industry members must still report transformed social security numbers (SSNs) or individual taxpayer identification numbers (ITINs) for natural persons and, to the extent applicable, Larger Trader IDs (LTIDs) and Legal Entity Identifiers (LEIs).
FINRA Publishes 2025 Annual Regulatory Oversight Report
On January 28, the Financial Industry Regulatory Authority (FINRA) published the 2025 update to its annual Regulatory Oversight Report.1 The report collects recent observations and findings from FINRA's oversight programs – Member Supervision, Market Regulation and Transparency Services, and Enforcement – and provides FINRA member firms with a helpful resource to evaluate compliance on a number of cutting-edge topics.
FINRA Publishes 2025 Annual Regulatory Oversight Report - A Window Into Best Practices and FINRA's Focus in a New Regulatory Environment | JD Supra
On January 28, the Financial Industry Regulatory Authority (FINRA) published the 2025 update to its annual Regulatory Oversight Report.1 The report collects recent observations and findings from FINRA's oversight programs – Member Supervision, Market Regulation and Transparency Services, and Enforcement – and provides FINRA member firms with a helpful resource to evaluate compliance on a number of cutting-edge topics.
FINRA Publishes 2025 Annual Regulatory Oversight Report
On January 28, the Financial Industry Regulatory Authority (FINRA) published the 2025 update to its annual Regulatory Oversight Report.1 The report collects recent observations and findings from FINRA's oversight programs – Member Supervision, Market Regulation and Transparency Services, and Enforcement – and provides FINRA member firms with a helpful resource to evaluate compliance on a number of cutting-edge topics.
Alpine v. FINRA Big News
On November 22, the US Court of Appeals for the District of Columbia Circuit granted Alpine a preliminary injunction, ruling that the Financial Industry Regulatory Authority (FINRA) cannot expel Alpine without the Securities and Exchange Commission's (SEC) review.
Post-Election Shift: Securities Industry Anticipates Business-Friendly SEC Under Trump Administration
Post-election, securities industry professionals are pondering the new administration's impact on the regulatory environment and their businesses. While there is no sure outcome, many comfortably predict that under the Trump administration, the Securities and Exchange Commission (SEC or Commission) will be a more business-friendly environment, particularly with respect to digital assets.
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