The first quarter of 2024 was marked by a measured shift in the SEC’s aggressive rulemaking agenda. Following legal challenges filed in 2023 opposing the expansive Private Fund Rulemaking, a three-judge panel of the U.S. Court of Appeals for the Fifth Circuit heard oral arguments in the private fund rule challenge in early February 2024. Subsequently after the quarter, in June 2024, the court issued its opinion that the SEC exceeded its statutory authority in adopting the Private Fund Rules and the court vacated the entire final rulemaking. Legal challenges surrounded other recent SEC rulemaking, setting the stage for the SEC to voluntarily stay its final public company climate disclosure rules which it passed on March 6, 2024. The SEC has experienced significant turnover in staff in its rulemaking divisions and is operating under an effective hiring freeze, which is also impacting examination and enforcement staff. Nevertheless, the agency continued an active examination agenda throughout the first quarter of the year.