NYC advances proposed rules on subscription cancellations, expanding enforcement against negative option offers and outlining new disclosure and notice requirements.
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Prediction Markets: A CFTC Enforcement Update
CFTC DoE Director David Miller highlighted prediction markets and crypto assets as perhaps the two most dynamic markets in finance during his March 2026 remarks at NYU Law School.
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FTC Seeks Comment on Potential Updates to Negative Option Rule
On March 11, 2026, the Federal Trade Commission issued an Advance Notice of Proposed Rulemaking seeking public comment on whether it should amend its Rule Concerning the Use of Prenotification Negative Option Plans.
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CFTC Regulatory Developments on Prediction Markets and Event Contracts
Prediction markets are electronic trading platforms where participants buy and sell interests in future event outcomes, from elections to economic indicators. Prices reflect aggregate probability, with event contracts typically offering binary yes or no outcomes.
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California DPFI Suspends Implementation, Enforcement of State’s New Investor Law
On March 17, 2026, the California Department of Financial Protection and Innovation announced it would suspend implementation of the California Fair Investment Practices by Venture Capital Companies Act.
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SEC Clarifies Status of Crypto Assets Under Federal Securities Laws, Signals Potential Exemptive and Safe Harbor Framework
On March 17, 2026, the U.S. Securities and Exchange Commission issued an interpretive release addressing the application of the federal securities laws to crypto assets and related transactions.
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FTC Seeks Comment on Potential Rule to Address Unfair or Deceptive Rental Housing Fee Practices
On March 12, 2026, the Federal Trade Commission issued an Advanced Notice of Proposed Rulemaking seeking public comment on a proposed rulemaking to address potential unfair or deceptive fee practices in connection with rental housing.
SEC Issues Extension for Compliance with Section 16(a)
The U.S. Securities and Exchange Commission recognized that processing delays associated with the unusually large number of Form ID applications being submitted due to the Holding Foreign Insiders Accountable Act may contribute to FPIs failing to meet the March 18, 2026, deadline to comply with such Section 16(a) reporting requirements.
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Compliance Deadline Approaches for FinCEN’s Residential Real Estate Reporting Requirements
Effective March 1, 2026, FinCEN’s Residential Real Estate Rule will impose streamlined reporting (the Real Estate Report) and recordkeeping requirements on certain persons involved in residential real estate closings and settlements (collectively, Reporting Persons).
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SEC Enforcement Director Makes First Public Remarks on the Wells Process and Enforcement Priorities
On Aug. 21, 2025, Judge Margaret Ryan, a former senior judge of the United States Court of Appeals for the Armed Forces, was named the Securities and Exchange Commission’s director of the Division of Enforcement.
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