May 5, 2025
The Suggestion Box: What SEC Rules Do You Not Like?
The Trump Administration moved quickly in its first 100 days to implement the “deregulation” part of its regulatory agenda. We’ve shared a number of deregulation developments on TheCorporateCounsel.net, including:
– The first deregulation Executive Order saying that whenever an agency promulgates a new rule, regulation, or guidance, it must identify at least 10 existing rules, regulations, or guidance documents to be repealed;
– The second deregulation Executive Order and subsequent memo saying all agency heads should prioritize repealing regulations that could be struck down as overreach or otherwise unlawful under recent Supreme Court cases, and do so without notice and comment where consistent with the Administrative Procedure Act’s “good cause” exception (likely to be litigated);
– A letter from members of the House Financial Services Committee to then Acting Chairman Uyeda calling on the SEC to withdraw several final and proposed rules — notably including two Corp Fin rules, one being Pay Versus Performance; and
– Most recently, the Trump Administration’s new suggestion box for the public to “submit your deregulatory vision” — i.e., a new online form on Regulations.gov run by the General Services Administration and the Office of Management and Budget where the public can submit ideas for bothersome rules and regulations they’d like to see on the chopping block.
In his blog on the suggestion box, Dave asked, “Which SEC rules and regulations are you going to drop a dime on to the GSA/OMB?” So let’s run an anonymous quick poll!
This poll is all just fun and games, but I should note that some of these rules are Congressionally mandated, in which case it’s not likely that they’d be done away with completely, but I’m sure there are tweaks we’d all welcome!
– Meredith Ervine