US Asset Management Regulatory Year in Review 2025

Over 2025, US financial regulators undertook a broad recalibration of their approach to market regulation, marked by a noticeable shift toward deregulatory initiatives, clarifying guidance, and a renewed emphasis on flexibility over prescriptive rulemaking. Regulatory agencies revisited prior regulatory positions, withdrew or delayed significant proposals, and issued targeted relief in areas ranging from fund naming conventions and marketing disclosures to crypto custody, co-investments, and anti-money laundering obligations.

The Securities and Exchange Commission (SEC) issued multiple statements and frequently asked questions clarifying that certain stablecoins, staking activities, and crypto custody arrangements fall outside traditional securities regulation. The White House inter-agency Working Group on Digital Asset Markets advanced a formal taxonomy for security tokens, commodity tokens, and commercial-use tokens, and Congress enacted the Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act) to establish a federal stablecoin regime—leaving broader market structure reforms under the Digital Asset Market Clarity Act of 2025 (CLARITY Act) framework still under negotiation.

For asset managers and investment funds, the period also brought meaningful structural and operational changes, such as modernized co-investment rules for registered funds and business development companies, simplified verification requirements for private offerings under SEC Rule 506(c), an easing of SEC Rule 206(4)-1 (the Marketing Rule) constraints on performance presentation, approval of multicrypto exchange-traded products, and more.

Collectively, the developments reflected a sustained regulatory pivot away from enforcement-driven expansion and toward legal clarity, institutional accommodation, and market-driven innovation—redefining the operating environment for financial institutions, digital asset platforms, and investment managers alike.

In this edition we identify the key priorities in the SEC's regulatory agenda under newly appointed Chair Paul Atkins and anticipate what the SEC is expected to do moving forward.

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