FinTech Law

The SEC just repudiated its predecessor's enforcement program — on the record.

Chairman Atkins's FY2025 enforcement results aren't just a scorecard. They're a policy statement. And if your compliance program was built around the prior Commission's priorities, it needs an update.

Here's what changed:

✗ Off-channel communications cases — 95 actions and $2.3B in penalties under the prior Commission, now characterized as "no direct investor harm" and a misallocation of resources.

✗ Crypto registration cases — 7 enforcement actions dismissed, including Coinbase, Binance, and Consensys. The "are you registered?" era is over.

✗ Novel dealer definition theories — explicitly repudiated.

Here's what didn't:

→ Offering fraud — including in crypto token offerings. Unicoin's executives found this out the hard way.
→ Fiduciary duty enforcement — the Vanguard conflict of interest action and the FamilyWealth advisory agreement action are the new roadmap.
→ Individual accountability — two-thirds of standalone actions charged individuals. 119 officer and director bars obtained.
→ Self-reporting and cooperation — firms that surfaced issues early received meaningfully better outcomes.

The enforcement reset is real. But it has sharp edges.

Read the full analysis → https://zurl.co/Vw5bp

SEC FY2025 Enforcement Results: What Fintech & Digital Asset Firms Must Know The SEC's FY2025 enforcement results signal a fundamental reset — away from volume and novel legal theories, toward fraud, individual accountability, and investor protection. Here's what it means for fintech startups and digital asset firms.

The latest issue of The Startup Solution is out now → https://zurl.co/jwVMC

It covers the biggest regulatory shift of the quarter — and what it means for founders building in crypto, digital assets, and legal tech.

What's inside:

→ SEC-CFTC Harmonization. For the first time, both agencies are coordinating on digital asset oversight. One MOU. One joint interpretive release. The jurisdictional turf war that has cost crypto founders millions is ending. The clarity is real. The compliance work is not done.

→ The Tokenization Hearing. On March 25, Congress reached a bipartisan verdict: tokenized securities are coming whether the legal framework is ready or not. The CLARITY Act has weeks to move — or it waits years. $26.5B in real-world assets are already on-chain. This is not theoretical.

→ What AI-Native Law Firms Actually Look Like. When Blackstone invested $50M in Norm Ai, it validated what we have been building at FinTech Law for two years. The distinction between AI-adopting and AI-native is real — and the gap widens every year.

→ Compliance deadlines through June 2026 — Form PF, Regulation S-P, EDGAR Next, and the Regulation Crypto Assets comment window.

→ Introducing .ai — attorney-reviewed legal documents for startups, built by FinTech Law and .

The Startup Solution: AI for Legal Teams, April 2026 SEC-CFTC harmonization framework, tokenization hearing analysis, AI-native law firms, compliance deadlines through June 2026, and introducing Enzio. Download the full PDF.

The CFPB just proposed cutting its workforce from 1,758 to 556 — including an 80% reduction in enforcement staff.

The instinct to exhale is understandable. Resist it.

The CFPB's statutory authority doesn't shrink with its headcount. The Consumer Financial Protection Act, TILA, EFTA, and federal money transmitter rules remain fully in force regardless of how many examiners are on payroll.

What actually changes:

→ State AGs and financial regulators are moving to fill the vacuum. New York, California, and Illinois have each signaled expanded consumer financial protection enforcement. A compliance program built around CFPB-primary oversight now faces a patchwork of state regulators, each with independent authority.

→ Private litigation risk rises when agency enforcement drops. Plaintiffs' attorneys watch enforcement gaps closely. Provisions your terms of service or privacy policy that a fully staffed CFPB might have flagged in an exam are now more likely to be tested in a class action.

→ The supervision gap is real. The liability gap is not.

For fintech startups and digital asset companies: this is not a compliance holiday. It is a window to build compliance infrastructure that doesn't depend on any single agency's capacity to enforce it.

We break down exactly what to do — and what not to assume — on our blog: https://zurl.co/MCIbq

CFPB Cuts & Fintech Compliance: What Startups Must Do The CFPB is cutting two-thirds of its workforce. Fintech startups still face full legal exposure. Here is what your compliance program must address right now.

⚖️ The SEC published three major reports in a single day. Here's what they mean for your compliance program.

The March 2026 edition of The Financial Edge breaks down the findings — and translates them into action.

🔹 Active ETFs Now Rival Passive Funds in Number — and the risk profile is different. DERA confirmed higher turnover, greater derivatives usage, and lower benchmark alignment. If your compliance framework was built for passive strategies, it needs an upgrade. Rule 18f-4, Rule 6c-11, and Section 15(c) are all in play.

🔹 Fund Mergers Cut Fees, But Not Equally — DERA analyzed 1,800+ mergers and found that mixed and bond funds benefit most, equity funds least, and within-family mergers (the most common structure) showed the weakest fee impact. If a merger is on your board's agenda, this data should inform your Section 15(c) analysis.

🔹 Private Markets Now Raise Twice as Much as Public Markets — Rule 506(b) alone accounted for $1.8 trillion in FY2024 versus $28 billion in IPOs. With Chairman Atkins signaling Regulation D reform and accredited investor expansion, the regulatory tailwinds may strengthen.

🔹 The $150,000 Boilerplate Warning — The SEC charged FamilyWealth Advisers for language most firms consider routine: hedge clauses, assignment provisions, and custody obligations buried in trading authorization language. Your advisory agreement is a regulatory document. Review it before examiners do.

🔹 Compliance Corner — Critical deadlines through June 2026, including the March 31 Form ADV amendment, the June 3 Reg S-P deadline (no extension granted), and EDGAR Next enrollment.

🔹 Enzio — Startup Legal Documents, Attorney-Reviewed. 29 document types built by FinTech Law and Rikka. Startup-friendly pricing, no $25K retainer required.

The bottom line: the SEC's February reporting activity was not routine. It signals where examination and enforcement attention is heading in 2026 — and compliance programs built for yesterday's market need to catch up.

📖 Read the full March 2026 edition: https://zurl.co/ahfQT

What's the compliance obligation your team is most focused on heading into Q2? Let us know in the comments. 👇

The Financial Edge: SEC Compliance for Fund Boards & Advisers, March 2026 Active ETF compliance, fund merger fee analysis, private markets capital raising, SEC hedge clause enforcement, compliance deadlines through June 2026, and Enzio. Download the full PDF.