On September 4, 2025,  the SEC’s Office of Information and Regulatory Affairs released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions. This is the first regulatory agenda released by the Atkins-led SEC. It signals the known focus of this administration on deregulatory proposals and reducing compliance burdens and disclosure costs, in keeping with the administration’s goal of a renewed focus on supporting capital formation and market efficiency. Key takeaways include:

• Innovation and deregulation. A number of deregulatory provisions would simplify pathways to raising capital and provide for expanded investor access to private businesses. Revisiting numerous existing reporting and disclosure frameworks could reduce compliance burdens.
• Crypto a top priority. The deregulatory and review agenda directives may help clarify the regulatory framework for crypto assets across various areas of the market, including issuance, custody, and trading.
• Clear shift from the prior administration. The SEC also withdrew several items that were on the previous administration’s agenda, which Commissioner Atkins noted were misaligned with the new administration’s approach. Withdrawn items material to private fund managers and investment advisers include, Safeguarding Advisory Client Assets, Conflicts Related to Predictive Data Analytics, ESG Disclosures, Cybersecurity Risk Management, Outsourcing by Investment Advisers, and Regulation D and Form D Improvements, among others.
• Staying in bounds. Atkins also noted the reasoning for withdrawal of many prior administration regulations was due primarily to their misalignment with the current goal of being smart and effective but regulating in a way that is appropriately tailored to the confines of the SEC’s statutory authority.
• Noteworthy rulemaking still in scope. Two items that could materially impact private fund managers and investment advisers that remain on the agenda are Custody Rule Amendments (with potential clarification regarding crypto and other asset classes) and Customer Identification Programs (related to the FinCEN AML Rules that were previously adopted but for which the compliance date was recently pushed from 1/1/26 to 1/1/28).