September 30 marked the end of the SEC's fiscal year and the last day before the federal government shutdown. Q3 included notable developments and announcements by the SEC including, among others: 1) the appointment of new Directors of the Divisions of Enforcement and Corporation Finance; 2) a new Cross-Border Task Force; 3) a new era of collaboration between the SEC and CFTC; 4) a new Artificial Intelligence (AI) Task Force and AI examination initiative; 5) continued activities by the Crypto Task Force with a renewed vision at modernizing regulations as part of "Project Crypto;" 6) numerous new enforcement actions, focused on traditional areas such as disclosure fraud, insider trading and market manipulation, and breaches of duties by registrants; and 7) the dismissal of a number of active enforcement investigations, particularly those involving technical, non-fraud violations and relatively novel legal theories.

Most enforcement investigative and examination activity has been effectively halted during the government shutdown, as only essential activities are conducted during this period. This has resulted in a pause for ongoing examinations and will likely result in a delay in initiating new exams and completing open exams. However, we expect these activities to resume to their normal course once the shutdown is resolved. While there have been many indications of the priority shift under the leadership of Chairman Atkins, there may be a delay in publishing the 2026 Examination Priorities (which were published in October for the prior two fiscal years). The Standish Compliance team continues to track and analyze regulatory developments and their impact on our private fund and other clients. Let us know if you have questions regarding any regulatory developments or their application to your firm.