Two recent developments signal where the Securities and Exchange Commission (the SEC) is headed in 2026. First, SEC Chairman Paul Atkins’ address at the New York Stock Exchange (NYSE) on December 2, 2025 set forth guiding principles for reform with the goal to, in Chairman Atkins’ words, “make IPOs great again.”

The U.S. Securities and Exchange Commission (SEC) case against SolarWinds and its Chief Information Security Officer has been dismissed, closing a high-profile cybersecurity enforcement action. This comes as SEC actions against public companies have dropped 30% year-over-year, with the lowest level of enforcement action since 2012—highlighting a notable slowdown in regulatory activity.

On December 5, 2025, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued a joint statement (the Statement) rescinding the Interagency Guidance on Leveraged Lending, issued March 2013 (the 2013 Guidance), as well as the Frequently Asked Questions for Implementing March 2013 Interagency Guidance on Leveraged Lending, issued February 2014 (the 2014 FAQs). The Federal Reserve, which co-signed both documents, has not yet indicated whether it will follow suit, but one would expect larger state-chartered banks that are members of the Federal Reserve System (and thus supervised by the Federal Reserve) to lobby the Federal Reserve for equal treatment on this important issue to maintain a level playing field with their national bank and state-chartered, FDIC-supervised bank competitors.