Publications

November 2025 witnessed increased industry attention for the European Union’s (EU) ongoing efforts to reform the regulatory frameworks applicable to securitisations. Further to our recent memo on three recent regulatory developments relating to the EU/UK securitisation markets, this memorandum sets out key takeaways from the Joint Statement: Investors’ Views on the Securitisation Review, published jointly by the Association for Financial Markets in Europe, Alternative Investment Management...

On 20 November 2025, the European Commission published its final proposals to overhaul the EU Sustainable Finance Disclosure Regulation (SFDR). The proposals present a radical departure from the original SFDR regime and move from a disclosure-based approach to a regime that establishes distinct investment categories with minimum sustainability standards that must be met by financial products making certain sustainability-related claims. The proposals follow on from an unofficial leak of an...

On November 18, with the initial reporting deadline of January 1, 2026 rapidly approaching under California’s climate reporting law SB 261 (the Climate-related Financial Risk Act), the U.S. Court of Appeals for the Ninth Circuit granted a motion for injunction pending appeal of the law. On the same day, the California Air Resources Board (“CARB”) proceeded with its third Virtual Public Workshop to provide guidance and updates to implementation of both SB 261 and SB 253 (the Climate Corporate...

Recent EU and UK regulatory initiatives signal a renewed push to strengthen and scale the EU and UK securitisation markets, with three developments in particular highlighting how policymakers aim to broaden the investor base, refine prudential frameworks and mobilise long-term capital—especially from insurers. 1. ECON Committee hearing to assess the securitisation package amending the European Securitisation Regulation[1] (EUSR) and the Capital Requirements Regulation[2] (CRR) (13 October...

On November 18, 2025, the Federal Reserve released a Statement of Supervisory Operating Principles that sets out changes to how Federal Reserve examiners should supervise banking organizations. The Statement translates Vice Chair for Supervision Michelle Bowman’s stated priorities into concrete operating expectations for supervisory staff at the Federal Reserve Board and Federal Reserve Banks. The Statement follows an August 6, 2025, internal communication to Federal Reserve supervisory staff...

On November 17, 2025, the SEC’s Division of Corporation Finance announced that, during the 2025–2026 proxy season, due to resource constraints following the government shutdown and the breadth of existing guidance issued by the staff, the SEC staff will not respond to no-action requests or express views on companies’ intended reliance on Rule 14a-8 for exclusion of shareholder proposals in their proxy materials, except for requests related to state-law based exclusions under Rule...

This week FTC Commissioner Melissa Holyoak identified three top priorities for the Commission in her remarks at the Association of National Advertisers Master of Advertising Law Conference. The priorities include protecting children and teens, with aggressive enforcement of the Children’s Online Privacy Protection Act (COPPA), enforcing its Made in U.S.A. Rule, and ensuring price transparency, with a reference to enforcing the Restore Online Shoppers’ Confidence Act (ROSCA). The Commissioner...

Executive Summary On October 22, 2025, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) designated two of Russia’s largest oil companies—Open Joint Stock Company Rosneft Oil Company (“Rosneft”) and Lukoil OAO (“Lukoil”)—and certain of their subsidiaries as Specially Designated Nationals (“SDNs”). A concurrently-issued general license authorizes wind-down transactions until November 21, 2025, but absent authorization, U.S. persons[1] are otherwise prohibited from...