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D.C. Insider July 2025: SEC Withdraws Proposed Rulemakings, Global Conflicts and Cyber Warnings, and More

 

In the July 2025 edition of The ICR D.C. Insider, we offer insights and analysis about recent developments in Washington including the SEC’s withdrawal of 14 proposed rulemakings, a re-examination of executive compensation disclosures, cyber warnings due to global conflicts, and more. Learn what could have an impact on your business. 

Tariffs & Trade

SEC

  • 14 Rule Proposals Withdrawn – The Securities and Exchange Commission (SEC) withdrew 14 proposed rulemakings across a wide range of issues. The rescinded proposals – originally issued between March 2022 and November 2023 under previous Chair Gary Gensler – focused on a wide range of complex issues, including predictive data analytics, custody of client assets, cybersecurity, ESG disclosures (for Investment Advisers and Investment Companies), trading practices and broker-dealer regulations. Industry experts and legal practitioners view the move as a clear signal of the SEC’s new direction under Chairman Paul Atkins, with an emphasis on more pragmatic, less prescriptive regulation. The withdrawn proposals include:
    • Shareholder Proposals
    • Predictive Data Analytics
    • Safeguarding Advisory Client Assets
    • Cybersecurity Risk Management for Investment Advisers, Investment Companies, and Business Development Companies (BDCs)
    • ESG Disclosures for Investment Advisers and Investment Companies
    • Outsourcing by Investment Advisers
    • Prohibition Against Fraud in Connection with Security-Based Swaps; Undue Influence Over Chief Compliance Officers (CCOs)
    • Regulation Best Execution
    • Volume-Based Exchange Transaction Pricing
    • Order Competition Rule
    • Regulation Systems Compliance and Integrity (SCI)
    • Cybersecurity Risk Management for Broker-Dealers, Clearing Firms, and Other Market Participants
    • Amendments to Exchange Act Rule Regarding Definition of “Exchange”
    • Proposed Amendments to the National Market System (NMS) Plan Governing the Consolidated Audit Trail (CAT) to Enhance Data Security
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  • Executive Compensation Disclosures to be Reexamined – At an SEC roundtable on executive pay disclosure, Chairman Atkins and his fellow Republican commissioners signaled they’re preparing for a major overhaul of how corporate leaders’ compensation is publicly reported, saying, “today, one might describe the Commission’s current disclosure requirements as a Frankenstein patchwork of rules.” And they made clear their intention to put a simpler – and more business friendly – regime in place. As Commission staff considers several questions in this area public comment letters are also being encouraged.
  • Concept Release on Updating the Definition of Foreign Private Issuer Announced – The SEC published a concept release to solicit public comment on the definition of a foreign private issuer. Foreign private issuers benefit from certain accommodations and exemptions from the disclosure and filing requirements of federal securities laws. The concept release solicits public input on whether the definition of foreign private issuer should be amended in light of significant changes in the population of foreign private issuers since 2003.
  • Ongoing Talks to Encourage More Public Listings, Ease Regulations – U.S. exchange operators (NYSE and NASDAQ) are in talks with the SEC to ease regulatory burdens for public companies, as they seek to encourage more richly valued startups to list, Reuters reported. The reforms under discussion range from reducing the quantum of disclosures and the costs of going public to making it harder for minority investors to agitate. The conversations also include making it easier for companies that went public through deals with special purpose acquisition companies (SPACs) to raise capital.

DOJ

  • Areas for Priority Enforcement Focus Identified – Justice Department Criminal Division head Matthew Galeotti said a company can expect to receive a declination to prosecute when it voluntarily reports potential wrongdoing to the Justice Department, cooperates with subsequent investigations, and remediates violations.

Congress

  • Antitrust Probe of Proxy Advisors Sought – Sen. Bill Hagerty (R-Tenn.), who leads the Senate Banking Committee’s working group focused on proxy advisers, called on Attorney General Pam Bondi and Federal Trade Commission (FTC) Chair Andrew Ferguson to investigate Institutional Shareholder Services Inc. (ISS) and Glass, Lewis & Co. for antitrust violations. He points to the companies’ combined market share, saying that “these foreign-owned firms exploit their market power to suppress competition, hijack corporate governance, impose ideological agendas, drive companies’ capital allocation decisions, influence U.S. public policy on important matters, and undermine the welfare of American investors and consumers.”

Cyber

  • Global Conflicts Trigger Cyber WarningsU.S. cybersecurity organizations are urging businesses to remain on high alert given the current conflicts around the world, including in the Middle East. The Food and Ag-ISAC and the IT-ISAC (ISAC’s are non-profit organization that augments member companies’ internal capabilities via information sharing and best practices) published a joint statement urging companies to proactively bolster their defenses, noting a history of Iranian state-sponsored hackers and hacktivism targeting U.S. critical infrastructure during previous conflicts. Radware, a U.S.-based cybersecurity firm, estimated there’s been a 700% increase in Iranian cyberattacks against Israeli targets since Israel launched its initial missile strike on Tehran on June 12.

China

  • U.S. Considering Further Crackdown on Semiconductor Export Licenses – Jeffrey Kessler, Under Secretary of Commerce for Industry and Security (BIS), reportedly told three large semiconductor manufacturers (Samsung Electronics, SK Hynix, and Taiwan Semiconductor Manufacturing) that the current blanket waivers that allow them to ship American chip-making equipment to their factories in China without applying for a separate license each time could be coming to an end. Kessler, and other national security advocates, have taken a hard line on cutting off China from American technologies, arguing that aggressive measures are needed to limit the country’s advances in critical sectors and spur development of supply chains outside China.
  • House Committee Acts to Strengthen U.S. Security Around AI – The House Select Committee on the Chinese Communist Party introduced a new bipartisan bill to help strengthen U.S. national security surrounding artificial intelligence. The Advanced AI Security Readiness Act would direct the National Security Agency (NSA) to create an “AI Security Playbook” that would help to identify weaknesses in U.S. artificial intelligence systems and defend against cyberattacks. The legislation also underlines cybersecurity standards and details U.S. plans for secure government-supported AI systems.