On September 4, 2025, the Office of Information and Regulatory Affairs released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions. This release outlines the short- and longer-term regulatory actions of the SEC and its various departments.

The Spring 2025 agenda contains 23 rulemaking items across various stages: 3 in the prerule stage, 18 at the proposed rule stage, and 2 in the final rule stage.

Key investment management-related proposals on the agenda are as follows:

Rulemaking	Status and Timing
Crypto Assets	Proposed Rule Stage, April 1, 2026
Crypto Market Structure Amendments	Proposed Rule Stage, April 1, 2026
Amendments to Rule 17a-7 Under the Investment Company Act	Proposed Rule Stage, April 1, 2026
Amendments to the Custody Rules	Proposed Rule Stage, April 1, 2026
Transfer Agents	Proposed Rule Stage, April 1, 2026
Amendments to Broker-Dealer Financial Responsibility and Recordkeeping and Reporting Rules	Proposed Rule Stage, April 1, 2026
Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers	Final Rule Stage, April 1, 2026

Key Highlights of the Spring 2025 Agenda:

                Crypto-related Proposals

The SEC’s agenda features several proposals related to digital assets and crypto market regulation. These developments were much anticipated as the SEC began laying the groundwork for these changes through its establishment of the Crypto Task Force,¹ and addressed these topics in various contexts, including public statements, industry roundtables, the President’s Working Group on Digital Asset Markets,² and Chairman Paul Atkins’ rollout of “Project Crypto.”³ The scope and diversity of crypto-focused rule proposals reflect a coordinated regulatory push under the current administration. These crypto-related rule proposals, which are summarized below, include “Crypto Assets,” “Amendments to the Custody Rules,” “Transfer Agents,” “Crypto Market Structure Amendments” and “Amendments to Broker-Dealer Financial Responsibility and Recordkeeping and Reporting Rules.”

• Crypto Assets and Digital Market Infrastructure: The SEC is proposing new rules relating to the offer and sale of crypto assets, including potential exemptions and safe harbors. These proposals may help simplify compliance for crypto companies while maintaining protections for investors.

• Alternative Trading Systems (ATSs): The current agenda outlines proposed changes to the Exchange Act rules that would apply to the trading of crypto assets on both Alternative Trading Systems (ATSs) and national securities exchanges. These developments represent an important effort to bring crypto trading more fully within the existing financial market structure.
• Distributed Ledger Technology (DLT): The SEC is proposing new requirements for transfer agents that address the use of DLT, the foundation behind many digital assets.  These rules are intended  to improve the transparency and operational efficiency of securities processing.
• Broker-Dealer Regulations: The SEC plans to update rules on financial responsibility and recordkeeping for broker-dealers, which would include amending rules 15c3-1 and 15c3-3 and other broker-dealer financial responsibility rules, as well as Rules 17a-3 and 17a-4, which aim to address the application of these rules to crypto assets.
• Custody of Assets: The SEC’s proposed amendments intend to improve and modernize the regulations around the custody of advisory client and fund assets, including the custody of crypto assets.

                Other Proposals

• Rule 144 Safe Harbor: The SEC is evaluating potential changes to the Rule 144 safe harbor to facilitate private market activity. These proposed changes would expand eligibility requirements and could reduce applicable compliance burdens, if adopted.

• Customer Identification Programs (CIPs) Rules: The SEC aims to issue a final rule implementing section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 with regard to certain investment advisers that, among other things, would require those investment advisers, as financial institutions under the Bank Secrecy Act, to implement reasonable procedures to verify the identities of their customers. The finalization of CIPs for registered investment advisers and exempt reporting advisers rule is expected by April 2026.  This indicates that FinCEN’s Anti-Money Laundering (AML) rule for investment advisers remains a focus. 

In June 2025, prior to the release of the Spring agenda, the SEC formally withdrew 14 rulemaking items issued in 2022 and 2023 which were proposed under the prior administration. In a statement issued together with the agenda, Chairman Atkins noted that “[i]mportantly, the agenda reflects our withdrawal of a host of items from the last administration that do not align with the goal that regulation should be smart, effective, and appropriately tailored within the confines of our statutory authority.”⁴ These withdrawals indicate a departure from the prior administration’s emphasis on environmental, social, and governance (ESG) initiatives and a movement toward deregulatory policies and market structure reforms.

Withdrawn proposals from the Division of Investment Management included:

• Safeguarding Advisory Client Assets (see prior S&K Guidance here)
• Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies, and Business Development Companies (see prior S&K Guidance here)
• Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices (see prior S&K Guidance here)
• Outsourcing by Investment Advisers (see prior S&K Guidance here)
• Conflicts of Interest Associated with the Use of Predictive Data Analytics by Broker-Dealers and Investment Advisers (see prior S&K Guidance here)

The current regulatory agenda reflects a broader reorientation of the SEC’s rulemaking priorities. Notably, the new agenda seems to indicate a transition from former Chair Gensler’s focus on digital asset regulation through enforcement to the current Chair’s focus on digital asset regulation through a structured rulemaking approach.

While the SEC’s regulatory agenda offers insight into the SEC’s current priorities and anticipated timelines, the timing of rule adoptions and proposals may vary and could come before or after dates listed in the regulatory agenda. As is typical of regulatory agendas adopted in the first year of a new SEC Chairmanship, the SEC’s Spring 2025 Agenda is fairly minimal. More detailed regulatory agendas appear as the current Chairman has more time to consider policy and new regulatory initiatives.

The SEC’s Spring 2025 Agenda can be found here. Chairman Atkins’ statement on the agenda’s release is available here.