September 17, 2025
What Happened?
SEC Chair Paul Atkins released a statement on Thursday, Sept. 4, 2025, announcing the Office of Information and Regulatory Affairs’ release of the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions. The regulatory agenda outlines the SEC’s list of forthcoming rulemakings, including those that are in the pre-rule stage, proposed rule stage, and final rule stage for Spring 2025. The regulatory agenda appears to be fairly consistent with the Office of Management and Budget’s accidental release of the SEC’s regulatory agenda last month, which was removed soon thereafter.
Among the proposed rules are unspecified amendments to Form N-PORT and a proposed rule regarding the offer and sale of crypto assets.
“A key priority of my Chairmanship is clear rules of the road for the issuance, custody, and trading of crypto assets while continuing to discourage bad actors from violating the law,” Atkins stated.
Pre-rule stage regulations include Foreign Private Issuer Eligibility, Asset-Backed Securities Registration and Disclosure Enhancements, and Evaluating the Continued Effectiveness of the Consolidated Audit Trail. The two regulations in the final rule stage are Financial Data Transparency Act Joint Data Standards and Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers.
What Does This Mean for Me?
Crypto is in—the agenda’s inclusion of a crypto asset proposal, a crypto market structure amendment, and a custody proposal to modernize custody regulations, including “to address … crypto assets” sends a clear message that the SEC intends to create a regulatory framework for crypto currency. However, these are just agenda items tentatively dated for the second quarter of 2026. We will have to wait and see how quickly the SEC follows through on completing the proposed rulemakings, publishing the proposals, and inviting public comments.
The spring agenda also includes amendments to Form N-PORT, the form on which many registered investment companies report certain portfolio-related information to address identified disclosure burdens. Earlier this year, the SEC decided to delay the compliance date for amendments to Form N-PORT, which were published on September 11, 2024. The amendments include more frequent reporting of monthly portfolio holdings, changes in reporting requirements related to entity identifiers, and reporting requirements for open-end funds regarding their use of certain liquidity risk management service providers. These amendments have been delayed to November 17, 2027, for large fund groups and May 18, 2028, for smaller fund groups.
