The outcome of the U.S. Presidential election in November 2024 will mean a new season at the Securities and Exchange Commission (SEC). Shortly thereafter, the SEC announced that Chairman Gary Gensler will step down on January 20, upon President-Elect Trump’s inauguration. In December 2024, Trump nominated former SEC Commissioner Paul Atkins to replace Gensler. Previously, Atkins served as an SEC Commissioner from 2002 to 2008 and as an SEC staff member from 1990 to 1994. He knows the SEC well, which should help him quickly contribute to what is likely to be a material shift in the SEC’s rulemaking agenda, enforcement, and other priorities.

Previously, in October 2024, the SEC announced the departure of Enforcement Director Gurbir Grewal and the appointment of agency veteran Sanjay Wadhwa as Acting Director and Sam Waldon as Acting Deputy Director. In December 2024, the SEC further announced the departures of the Directors of the Division of Corporation Finance and the Division of Trading and Markets. It is likely that other senior personnel may leave the agency in coming weeks, allowing the appointment of new staff that are clearly aligned with the new Chairman’s agenda.

SEC rulemaking nearly ground to a halt even before the election, after multiple challenges to prior rulemaking. As a result, much of the key rulemaking that were proposed in 2022 and 2023 remained pending as of the end of 2024. The SEC did continue to bring a significant number of new enforcement cases throughout Q4 in advance of the end of the calendar year.