Securities Regulation Daily Wrap Up, REGULATION TRACKER—Upcoming SEC and CFTC comment deadlines and effective dates, (Sep 14, 2026)

By WK Editorial Staff

A table of proposed rule comment dates and final rule effective and compliance dates for SEC and CFTC rulemaking.

Recent SEC activity includes the following:

Rescission of pay-to-play. The SEC proposed to rescind its "pay-to-play" rule prohibiting investment advisers from providing compensated investment advisory services to government clients for two years after making a political contribution to certain elected officials or candidates. Specifically, the proposal would rescind Advisers Act Rule 206(4)-5 (adopted in 2010) and amend the Advisers Act recordkeeping rule (275.204-2) to eliminate the provisions requiring a registered investment adviser to make and keep certain records in connection with the political contribution rule. Other requirements of the Advisers Act and associated rules, including prohibitions on fraud, fiduciary duty requirements, the compliance rule, and the code of ethics rule, would continue to apply.

Transfer agents. The SEC proposed to overhaul and modernize its rules for registered transfer agents. The proposal, which represents the first substantive change to the framework in forty years, would amend the registration and reporting requirements for transfer agents and modernize rules to reflect technological advancements. The proposal also contains new requirements related to turnaround, risk management, and inactive securityholders. Two new rules would require the establishment of compliance policies and address the placement and removal of restrictive legends.

EU debt obligations. The SEC proposed amendments to Exchange Act Rule 3a12-8 to add the debt obligations of the European Union (EU) to the list of foreign government debt obligations designated as "exempted securities" solely for the purposes of futures marketing and trading. The proposed amendments would place futures contracts on European Union debt obligations under the exclusive jurisdiction of the CFTC, consistent with the regulatory treatment already afforded to futures on the debt obligations of several EU member states currently listed under Rule 3a12-8. The offerings of the underlying debt obligations themselves would remain subject to the federal securities laws.

Regulation Crypto Assets. The SEC proposed "Regulation Crypto Assets" to create a new regulatory framework for non-security crypto assets subject to an investment contract. The proposed rules build on a March 2026 interpretation that clarified how the federal securities laws apply to certain crypto assets and transactions. The proposed rules would create two new exemptions for securities offerings and a conditional safe harbor from the term “investment contract.” The proposal would also preempt state securities law requirements for offers and sales of covered investment contracts issued pursuant to the regulations.

Regulation E-Delivery. The SEC proposed a new rule to make e-delivery the default standard for satisfying disclosure requirements. Currently, recipients have to opt in to electronic delivery; Regulation E-Delivery would allow entities to deliver information electronically without first obtaining affirmative consent. In order to rely on Regulation E-Delivery, the recipient must have provided an electronic address, and the entity must have provided a prominent disclosure to the recipient that it will send information electronically. The rule would permit two methods of e-delivery depending on whether or not the delivery includes personal financial information.

Please see the SEC Regulation Tracker for proposal comment deadlines and final rule compliance dates.

CFTC

Recent CFTC activity includes the following:

Whistleblower awards. The CFTC adopted a new final Rule 165.9(d) to create a presumption that whistleblower awardees will receive a 30 percent statutory maximum if the amount collected would yield a maximum award of $5 million and certain conditions are met. The rule is modeled on the SEC's rule 21F-6(c) as part of ongoing harmonization efforts.

Swaps clearing. The CFTC issued a final rule to modify its clearing requirement for Canadian dollar- and Mexican peso-denominated interest rate swaps. The rule removes the requirement to clear interest rate swaps referencing the Canadian Dollar Offered Rate and the Interbank Equilibrium Interest Rate, also known as TIIE, and replaces it with a requirement to clear CAD- and MXN-denominated interest rate swaps referencing overnight, nearly risk-free rates.

Form PF compliance date extension. The CFTC and SEC further delayed the compliance date for amendments to Form PF to July 1, 2027. The amendments were approved February 8, 2024 and address Form PF instructions and basic information, among other changes. Form PF is the confidential reporting form for certain SEC-registered investment advisers to private funds, including those also registered with the CFTC as a commodity pool operator (CPO) or commodity trading adviser (CTA). The extension of compliance date follows previous extensions to October 1, 2025 and October 1, 2026.

SEF order book requirement. The CFTC is seeking public comments on proposed amendments to CFTC regulation § 37.3(a)(2) to remove the order book requirement allowing swap execution facilities not to offer an order book for permitted transactions.

CPO/CTA registration exemptions. The CFTC is seeking comments on proposed amendments to part 4 of the CFTC’s regulations addressing registration requirements for commodity pool operators (CPOs) and commodity trading advisors (CTAs). The proposed amendments would add an exemption from CPO registration and related CTA registration for certain investment advisers registered with the SEC in relation to commodity pools for which the participants are limited to certain sophisticated investors and which meet other conditions. They would also increase the capital contribution threshold in the current CPO registration exemption for small commodity pools, also known as the small pool exemption, to reflect inflation.

Compute markets. The CFTC issued a request for comment to better inform its understanding and oversight of derivatives markets in compute. This request seeks comment on the size, liquidity, and other considerations with respect to compute cash markets, market oversight and manipulation concerns, customer protection, and perpetual compute futures. The request also welcomes comment on all aspects of the compute markets.

Affiliations between CFTC-registered entities. The CFTC proposed new rules and amendments to address increased affiliations between CFTC-registered entities—including derivatives clearing organizations, designated contract markets, swap execution facilities, futures commission merchants, and other market participants—such as market makers. The proposal addresses financial oversight, disclosure requirements, conflicts of interest, sharing of resources, and sharing of non-public information, among other topics.

Please see the CFTC Regulation Tracker for proposal comment deadlines and final rule compliance dates.

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