Rule2026-10132

Rescission of Policy Regarding Denials in Settlements of Enforcement Actions

Primary source

Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.

Published
May 21, 2026
Effective
May 21, 2026

Issuing agencies

Securities and Exchange Commission

Abstract

The Securities and Exchange Commission ("Commission") is rescinding a rule of informal procedure that concerns settlements in judicial or administrative proceedings.

Full Text

<html>
<head>
<title>Federal Register, Volume 91 Issue 98 (Thursday, May 21, 2026)</title>
</head>
<body><pre>
[Federal Register Volume 91, Number 98 (Thursday, May 21, 2026)]
[Rules and Regulations]
[Pages 29892-29896]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-10132]


=======================================================================
-----------------------------------------------------------------------

SECURITIES AND EXCHANGE COMMISSION

17 CFR Part 202

[Release Nos. 33-11417; 34-105504; IC-6965; IA-36158]
RIN 3235-AN77


Rescission of Policy Regarding Denials in Settlements of 
Enforcement Actions

AGENCY: Securities and Exchange Commission.

ACTION: Final rule.

-----------------------------------------------------------------------

SUMMARY: The Securities and Exchange Commission (``Commission'') is 
rescinding a rule of informal procedure that concerns settlements in 
judicial or administrative proceedings.

DATES: Effective May 21, 2026.

FOR FURTHER INFORMATION CONTACT: Samuel Waldon, Principal Deputy 
Director, Division of Enforcement, (202) 551-6000, Securities and 
Exchange Commission, 100 F Street NE, Washington, DC 20549.

SUPPLEMENTARY INFORMATION: Since 1972, the Commission has maintained a 
policy, codified in Rule 202.5(e) of its rules of informal procedure, 
17 CFR 202.5(e), that when it chooses to settle an enforcement action 
in which a sanction is imposed, it will not settle unless the defendant 
or respondent also agrees not to publicly deny the allegations in the 
complaint or administrative order. For the reasons explained below, the 
Commission now rescinds this policy and repeals Rule 202.5(e).

I. Background

    When the Commission exercises its authority to investigate and 
bring enforcement actions,\1\ it does not litigate every action to 
judgment. Like all parties to litigation, the Commission and a litigant 
against whom it brings a district court action or agency adjudication 
may agree to settle.\2\ The Commission's decision to settle depends on 
a range of factors, including the Commission's judgment that obtaining 
an immediate result by consent better serves the public interest than 
expending the resources and accepting

[[Page 29893]]

the risk that comes with fully litigating a matter.\3\ Similarly, a 
defendant's decision to settle turns on numerous factors.
---------------------------------------------------------------------------

    \1\ 15 U.S.C. 77t(b), 78u(a), (d)(1), 80a-41(d), 80b-14(a).
    \2\ We use the term ``settlement'' to refer to the resolution of 
enforcement actions by consent in which the Commission and a party 
against whom it has brought an action agree to terms to end that 
action, including agreed-upon sanctions. Settlements can include 
entry into consent judgments in district court and the acceptance of 
settlement offers in an order issued in an administrative 
adjudication.
    \3\ SEC v. Citigroup Glob. Mkts., 752 F.3d 285, 295 (2d Cir. 
2014) (``[The] factors that affect a litigant's decision whether to 
compromise a case or litigate it to the end include the value of the 
particular proposed compromise, the perceived likelihood of 
obtaining a still better settlement, the prospects of coming out 
better, or worse, after a full trial, and the resources that would 
need to be expended in the attempt.'' (cleaned up)).
---------------------------------------------------------------------------

    In a typical Commission settlement, a defendant in Federal district 
court signs a consent that describes the terms on which the parties 
have agreed to settle, or, in an administrative action, a respondent 
signs an offer of settlement that contains those terms.\4\ These 
documents reflect the defendant's (or respondent's) agreement and 
representation that the defendant (or respondent) is entering into the 
settlement knowingly and voluntarily. For actions in Federal district 
court, the Commission (sometimes jointly with the defendant) will then 
ask the court to enter a consent judgment that incorporates the terms 
of the consent and to retain continuing jurisdiction.\5\ For 
administrative adjudications, when the Commission accepts an offer of 
settlement, the terms are incorporated into an order instituting 
proceedings.
---------------------------------------------------------------------------

    \4\ The consent is a contractual agreement, signed by the 
parties, that reflects the terms of the settlement. It is a separate 
document from a judgment entered by a court, and its terms are 
usually repeated in the judgment or incorporated into that judgment 
by reference.
    \5\ Consent judgments are ``compromises in which the parties 
give up something they might have won in litigation and waive their 
rights to litigation.'' United States v. ITT Cont'l Baking Co., 420 
U.S. 223, 235 (1975). They ``embod[y] an agreement of the parties 
and thus in some respects [are] contractual in nature,'' but they 
are also ``enforceable as * * * judicial decree[s].'' Texas v. New 
Mexico, 144 S.Ct. 1756, 1764 (2024).
---------------------------------------------------------------------------

    In 1972, the Commission adopted Rule 202.5(e), which sets out a 
policy regarding settlements and is one of several ``informal and other 
procedures'' that concern enforcement activities.\6\ The policy stated 
the Commission's view at the time that in any civil lawsuit or in any 
administrative proceeding of an accusatory nature, ``it is important to 
avoid creating, or permitting to be created, an impression that a 
decree is being entered or a sanction imposed, when the conduct alleged 
did not, in fact occur.'' \7\ Accordingly, the Commission announced a 
``policy not to permit a defendant or respondent to consent to a 
judgment or order that imposes a sanction while denying the allegations 
in the complaint'' or administrative order.\8\ By limiting the 
circumstances under which the Commission will accept a settlement 
offer, the policy binds the staff of the Commission's Division of 
Enforcement (Enforcement) in settlement negotiations.
---------------------------------------------------------------------------

    \6\ 37 FR 25224 (Nov. 29, 1972), codified at 17 CFR 202.5(e). 
Congress bestowed upon the Commission ``the power to make such rules 
and regulations as may be necessary or appropriate to implement the 
provisions of this title for which [it is] responsible or for the 
execution of the functions vested in them by this title.'' 15 U.S.C. 
78w(a); accord 15 U.S.C. 77s, 80a-37, 80b-11; see also id. at 78u. 
The Commission has exercised this authority to adopt formal rules of 
procedure, 17 CFR 201.100 et seq., as well as informal procedures, 
such as Rule 202.5(e).
    \7\ Id.
    \8\ Id.
---------------------------------------------------------------------------

    The no-deny provisions that appear in settlements pursuant to this 
policy are usually paired with a statement that a defendant is not 
admitting the allegations (or liability). While the precise language 
has varied over time, defendants and respondents typically agree that 
they are entering into a consent without admitting or denying the 
allegations. More specifically, defendants and respondents agree, among 
other things, not to make `` `any public statement denying, directly or 
indirectly, any allegation in the complaint or creating the impression 
that the complaint is without factual basis.' '' \9\ The no-deny 
provisions do not, however, apply to testimonial obligations by 
defendants and respondents, and they do not affect their ability to 
take legal or factual position in litigation and other legal 
proceedings to which the Commission is not a party, including parallel 
civil actions.
---------------------------------------------------------------------------

    \9\ Powell v. SEC, 149 F.4th 1029, 1045 (9th Cir. 2025). The 
usual language states that a defendant ``will not take any action or 
make or permit to be made any public statement denying, directly or 
indirectly, any allegations in the complaint or creating the 
impression that the complaint is without factual basis'' and ``will 
not make or permit to be made any public statement to the effect 
that Defendants does not admit the allegations of the complaint, or 
that th[e] Consent contains no admissions of the allegations, 
without also stating that the Defendant does not deny the 
allegations.'' SEC v. Novinger, No. 4:15-cv-358, Dkt 33-1, at ] 12 
(N.D. Tex. June 3, 2016).
---------------------------------------------------------------------------

    For the most part, the Commission does not require settling 
defendants to make admissions.\10\ Together, these two components of 
settlement language have been referred to as the ``no admit/no deny 
policy.'' Thus, for over fifty years, when the Commission has settled 
on a no-admit basis, it has only agreed to cede its ability to prove 
its claims where the defendant has also agreed not to publicly deny the 
allegations in the complaint. Settlement brings certainty and closure 
without the risks and expenses of litigation, and often accelerates the 
Commission's ability to collect and, if feasible, distribute collected 
monetary sanctions to injured investors.
---------------------------------------------------------------------------

    \10\ See infra n.26 (discussing admissions).
---------------------------------------------------------------------------

    When the Commission agrees to settlements that contain no-deny 
provisions, the Commission has only a limited judicial remedy in the 
event a defendant breaches the settlement agreement by publicly denying 
allegations. In the event of a public denial, the Commission's only 
recourse, pursuant to the agreement, is to ask a court to vacate the 
settlement, returning the case to active litigation and permitting the 
Commission to prove its claims.\11\ And, as with all parties to a 
contract who are faced with a breach, the Commission may forgo this 
remedy, opting not to dedicate resources to reviving a once-settled 
case. Moreover, district courts have discretion to deny the 
Commission's request to return a case to the active docket in the event 
the Commission does seek relief in the wake of a breach. We are not 
aware of any instance where the Commission has sought to reopen a 
district court action or administrative adjudication following a 
violation of a no-deny provision, and there are no reported opinions 
where a court has ruled upon such a motion.
---------------------------------------------------------------------------

    \11\ There is a parallel procedure in administrative 
adjudications. In that context, when the Commission has accepted 
offers to settle, it has done so pursuant to Rule 202.5(e). 
Respondents have agreed not to publicly deny the allegations in the 
order instituting proceedings, and they further agreed that if they 
breached that agreement, Enforcement staff could ask the Commission 
to reopen the action against them.
---------------------------------------------------------------------------

    In recent years, there have been several challenges to no-deny 
settlements. Some defendants made unsuccessful efforts to alter no-deny 
provisions years after they agreed to consent judgments, arguing that 
the no-deny provisions violated their First Amendment rights and that 
the Commission did not comply with the Administrative Procedure Act in 
adopting the policy.\12\ Other parties have challenged the use of no-
deny provisions because they claimed they wanted to publish the speech 
of those who agreed to no-deny provisions.\13\ In a petition for 
rulemaking submitted to the Commission in 2018 and renewed in 2023, a 
petitioner asked the Commission to amend Rule 202.5(e) to provide that 
a defendant can consent to a judgment in which the defendant admits, 
denies, or neither admits nor denies the

[[Page 29894]]

allegations in the complaint.\14\ The Commission denied the petition 
(with one Commissioner issuing a statement dissenting from the 
denial).\15\
---------------------------------------------------------------------------

    \12\ SEC v. Romeril, 15 F.4th 166 (2d Cir. 2021); SEC v. 
Novinger, 40 F.4th 297 (5th Cir. 2022); SEC v. Novinger, 96 F.4th 
774 (5th Cir. 2024).
    \13\ E.g., Powell v. SEC, 149 F.4th 1029 (9th Cir. 2025) (3 of 
12 petitioners were described as media outlets that sought to report 
on defendants who signed no-deny provisions); Cato v. SEC, 4 F.4th 
91 (D.C. Cir. 2021) (holding that plaintiff lacked standing to seek 
declaratory judgment that Rule 202.5(e) was unconstitutional).
    \14\ Petition for Rulemaking, File No. 4-733 (Oct. 30, 2018), 
available at <a href="https://www.sec.gov/files/rules/petitions/2018/petn4-733.pdf">https://www.sec.gov/files/rules/petitions/2018/petn4-733.pdf</a>; Renewed Petition for Rulemaking, File No. 4-733 (Dec. 20, 
2023), available at <a href="https://www.sec.gov/files/rules/petitions/2023/petn4-733-renewed-petition-rulemaking-122023.pdf">https://www.sec.gov/files/rules/petitions/2023/petn4-733-renewed-petition-rulemaking-122023.pdf</a>.
    \15\ Letter to Margaret A. Little, File No. 4-733 (Jan. 30, 
2024) (Rulemaking Letter), available at <a href="https://www.sec.gov/files/rules/petitions/2024/4-733-letter-013024.pdf">https://www.sec.gov/files/rules/petitions/2024/4-733-letter-013024.pdf</a>. Commissioner Peirce 
filed a statement dissenting from the denial of the rulemaking 
petition. Commissioner Hester M. Peirce, Unsettling Silence: Dissent 
from Denial of Request for Rulemaking to Amend 17 CFR 202.5(e), 
available at <a href="https://www.sec.gov/newsroom/speeches-statements/peirce-nand-013024">https://www.sec.gov/newsroom/speeches-statements/peirce-nand-013024</a>.
---------------------------------------------------------------------------

    The Second and Ninth Circuits have held that the no-deny policy is 
constitutional.\16\ However, two judges in the Fifth Circuit (in a 
concurring opinion) have questioned whether the no-deny policy is 
constitutional.\17\ And while the Ninth Circuit rejected a facial 
challenge to the no-deny policy, declining to hold that the no-deny 
policy is per se unconstitutional, it also noted that the policy, as 
applied, could ``present different issues'' if the facts and 
circumstances of particular settlements ``sweep more broadly than Rule 
202.5(e) itself,'' which could implicate the ``important values 
associated with permitting criticism of the government.'' \18\ 
Additionally, the policy has been subject to criticism in the district 
courts.\19\
---------------------------------------------------------------------------

    \16\ Powell v. SEC, 149 F.4th 1029 (9th Cir. 2025); SEC v. 
Romeril, 15 F.4th 166 (2d Cir. 2021).
    \17\ SEC v. Novinger, 40 F.4th 297, 308 (5th Cir. 2022) (Jones, 
J., joined by Duncan, J., concurring).
    \18\ Powell, 149 F.4th at 1045, reh'g pet. denied, 2025 U.S. 
App. Lexis 27114 (9th Cir. Oct. 17, 2025). The petitioners have 
filed a petition for a writ of certiorari, which is currently 
pending. Powell v. SEC, No. 25-1100 (U.S.), available at <a href="https://www.supremecourt.gov/DocketPDF/25/25-1100/401007/20260316161817049_2026-03-16%20Powell%20et%20al.%20-%20Cert%20Petition%20with%20appendix.pdf">https://www.supremecourt.gov/DocketPDF/25/25-1100/401007/20260316161817049_2026-03-16%20Powell%20et%20al.%20-%20Cert%20Petition%20with%20appendix.pdf</a>.
    \19\ SEC v. Moraes, 2022 WL 15774011, *3 (S.D.N.Y. Oct. 28, 
2022); SEC v. Vitesse Semiconductor Corp., 771 F.Supp.2d 304, 309 
(S.D.N.Y. 2011).
---------------------------------------------------------------------------

II. Discussion

A. The Commission Is Rescinding Rule 202.5(e)

    After further consideration of the existing policy, the Commission 
is rescinding Rule 202.5(e). The Commission initiates enforcement 
actions only after determining that information obtained in an 
investigation indicates that a violation of the securities laws 
occurred or is about to occur.\20\ The commencement of such an 
enforcement action in district court (or institution of an 
administrative proceeding) reflects the Commission's intention to prove 
the facts of the case as alleged based on the results of that 
investigation.\21\ When the Commission chooses settlement to serve the 
public interest by obtaining a more certain and faster result with 
fewer expenditure of resources and less risk, it forecloses its ability 
to obtain findings of fact and conclusions of law.
---------------------------------------------------------------------------

    \20\ 15 U.S.C. 78u(a), (d).
    \21\ In an administrative proceeding, the Commission serves in 
an adjudicatory capacity.
---------------------------------------------------------------------------

    The Commission adopted Rule 202.5(e) on the view that it benefits 
the public interest ``to avoid creating, or permitting to be created, 
an impression that a decree is being entered or a sanction imposed, 
when the conduct alleged did not, in fact, occur.'' \22\ More 
specifically, a defendant who later denies the allegations can create 
the incorrect impression that there was no basis for the Commission's 
enforcement action, but only after the Commission yielded its 
opportunity to prove in court, under the rules of procedure and 
evidence, the facts that led it to commence the enforcement action in 
the first place.\23\ We conclude, however, that the negative effect on 
the public interest from such denials may be minimal. Moreover, we 
recognize that the policy itself may create the incorrect impression 
that the Commission is trying to shield itself from criticism, even 
though the main thrust of the policy was to allow the Commission, in 
the wake of a denial, to ask for the ability to test its allegations 
and legal theories.\24\
---------------------------------------------------------------------------

    \22\ 37 FR at 25224; see also Rulemaking Letter, at 4 (stating 
that when ``a defendant settles without admissions and then later 
denies the allegations, that turnabout can negatively impact the 
public interest'').
    \23\ Id. at 4-5.
    \24\ In Powell, the Ninth Circuit wrote that ``to the extent the 
SEC's letter addressing [the] request to amend Rule 202.5(e) 
advances the broader rationale that it is necessary to silence 
defendants in order to promote public confidence in the SEC's work, 
this rationale would be improper.'' Powell, 149 F.4th at 1044. The 
Ninth Circuit further stated that ``a defendant who denies the SEC's 
allegations may well undermine confidence in the SEC's enforcement 
programs. But undermining confidence in the government is an 
inevitable result of our robust First Amendment protections for 
speech critical of the government. The SEC's valid interest in Rule 
202.5(e) is thus more mechanical: that if a defendant wants to deny 
the allegations, the SEC wants to be able to prove those allegations 
in a particular forum, i.e., in court, with the benefits and 
protections of the judicial process.'' Id.; see also Moraes, 2022 
U.S. Dist. Lexis 196811, at *12 (expressing view that the 
Commission's policy exists to shield the agency from criticism).
---------------------------------------------------------------------------

    Four additional reasons support the Commission's recission of Rule 
202.5(e).
    First, the benefits to the Commission and the public from the 
policy, and the only remedy available under the policy, have proven to 
be limited over time. Under Rule 202.5(e), as implemented, if a 
settling defendant who has agreed to a no-deny provision then publicly 
denies the allegations, the Commission's only recourse is to ask a 
district court to vacate the settlement (or to reopen an adjudicatory 
proceeding).\25\ Thus, the policy existed in large part to ensure that 
the Commission did not irrevocably cede its ability to prove the 
allegations as part of a settlement. However, there is no known 
instance of the Commission exercising this option for administrative 
proceedings in the wake of a breach since Rule 202.5(e) was 
adopted,\26\ and the Commission is not aware of any instances in which 
the Commission asked a court to vacate a settlement in the wake of a 
breach, or that a court has agreed to such a request and reopened an 
enforcement action in the wake of a public denial.
---------------------------------------------------------------------------

    \25\ The Commission cannot seek an injunction for a violation of 
a no-deny provision, which is contractual in nature, and we are not 
aware of any instance in which the Commission sought injunctive 
relief for a claimed breach.
    \26\ Powell, 149 F.4th at 1036.
---------------------------------------------------------------------------

    Moreover, there is a built-in temporal disincentive to invoking 
this limited remedy. As the gap in time between the settlement and a 
(hypothetical) denial grows, the Commission will be less likely to 
dedicate resources to reopen a case where the allegations will be 
harder to prove due to the passage of time and the concomitant fading 
of memories and loss of evidence. Similarly, as more time elapses from 
the entry of a consent judgment containing a no-deny provision, a court 
may be less likely to grant the Commission's request to reopen an older 
case because of comparable procedural and evidentiary concerns. 
Particularly given that the Commission has not sought to use this 
remedy, any of its benefits do not justify retaining the rule.
    Second, technological changes in communication, particularly use of 
social media, have made the policy more challenging to implement. The 
no-deny provisions that implement Rule 202.5(e) cover public denials of 
allegations.\27\ The line between public and private statements, 
however, is not always clear, particularly for social media 
interactions that are intended for a private, self-selected community, 
but nonetheless are visible to dozens of individuals. Moreover, as the 
Ninth Circuit noted in upholding the no-deny policy against a facial 
constitutional challenge, the language of some consents ``could be read 
to sweep more

[[Page 29895]]

broadly than Rule 202.5(e) itself,'' by covering public statements that 
are `` `indirectly' '' denying allegations or `` `creating the 
impression' '' that the allegations are without a factual basis.\28\ 
Rather than have to parse whether such statements would trigger a no-
deny provision, the Commission chooses to repeal Rule 202.5(e).
---------------------------------------------------------------------------

    \27\ See, e.g., n.7 (quoting sample no-deny provision from a 
consent in the Novinger action, which, by its terms, only applies to 
a ``public statement'' of denial).
    \28\ Powell, 149 F.4th at 1044.
---------------------------------------------------------------------------

    Third, eliminating Rule 202.5(e) aligns the Commission with the 
majority of Federal agencies that do not have a similar rule.\29\ Most 
Federal agencies have not adopted a comparable no-deny policy, 
including the Department of Justice. Because nearly all other Federal 
agencies can settle enforcement actions without noticeable consequence 
even though the parties with whom they settle may deny the allegations 
against them after the time of settlement, we conclude that rescinding 
Rule 202.5(e) will not harm the public interest.
---------------------------------------------------------------------------

    \29\ See Verity Winship & Jennifer K. Robbennolt, Admissions of 
Guilt in Civil Enforcement, 102 Minn. L. Rev. 1077 (2018) 
(discussing differences in settlement practices between Federal 
regulators).
---------------------------------------------------------------------------

    Fourth, rescinding Rule 202.5(e) gives the Commission more 
flexibility in settling enforcement actions, which conserves resources, 
provides certainty, and may speed the return of money to injured 
investors (when feasible).\30\ The rule precludes the Commission from 
accepting settlements that lack a no-deny provision, and thus 
necessarily precludes settlements with defendants who do not wish to 
waive their rights by signing a no-deny provision that imposes a 
contractual obligation regarding denials that continues into the future 
beyond the time of settlement. The rescission of the rule will 
eliminate this restriction, allowing the Commission to better structure 
settlements resulting in collectible sanctions that can be returned 
(where feasible) to injured investors with fewer resources 
expended.\31\
---------------------------------------------------------------------------

    \30\ Armour, 402 U.S. 673 at 681 (parties settle ``after careful 
negotiation'' produce ``agreement on [a consent's] precise terms,'' 
saving ``themselves the time, expense, and inevitable risk of 
litigation,'' but also giving ``up something they might have won had 
they proceeded with the litigation''); Citigroup, 752 F.3d at 295 
(settlement provides ``parties with a means to manage risk'').
    \31\ There is no rule equivalent to Rule 202.5(e) regarding 
admissions. The Commission's rescission of Rule 202.5(e) does not 
affect its discretion to settle with defendants who decline to admit 
facts or liability, or its discretion to negotiate for admissions as 
part of a settlement. Moreover, there is a subset of cases where the 
Commission settles (or plans to settle) with a defendant or 
respondent that is the subject of a parallel criminal proceeding 
arising from the same or similar conduct, and where the defendant or 
respondent has pleaded, or is expected to plead, guilty, or been 
convicted. In those instances, there have been admissions (via an 
allocution) or a finding of criminal liability. For these types of 
cases, the Commission may continue to address admissions and denials 
in settlement agreements to ensure consistency between the 
Commission settlement and the resolution of the parallel matter.
---------------------------------------------------------------------------

B. The Commission Will Not Seek To Enforce Existing No-Deny Provisions

    In light of the rescission of Rule 202.5(e), and for the same 
reasons, the Commission will not enforce existing no-deny provisions in 
settlements that have already been entered. To the extent a settling 
defendant has previously agreed to a no-deny provision as part of a 
consent judgment entered in Federal court or administrative 
adjudicative order before the Commission, and the defendant then 
breaches the terms of that no-deny provision, the Commission will not 
seek or attempt to reopen an otherwise settled case. Rather, in the 
event of a breach of an existing no-deny provision, the Commission will 
take no action to ask a district court to vacate the settlement (or to 
reopen an adjudicatory proceeding) in connection with the settlement 
agreement and the limited relief the Commission has pursuant to its 
terms.

C. Administrative Law and Other Matters

    The Administrative Procedure Act (APA) generally requires an agency 
to publish notice of a proposed rulemaking in the Federal Register and 
provide an opportunity for public comment.\32\ This requirement does 
not apply, however, to ``interpretive rules, general statements of 
policy, or rules of agency organization, procedure, or practice.'' \33\ 
The Commission finds that the rescission of the no-deny policy 
constitutes a general statement of policy and relates solely to agency 
organization, procedure, or practice, and therefore notice and comment 
are not required.\34\ Similarly, the provisions of the Regulatory 
Flexibility Act of 1980, which apply only when notice and comment are 
required by the APA or another statute, are not applicable.\35\ 
Additionally, rescission of the no-deny policy does not impose or 
change any collection of information requirements as defined by the 
Paperwork Reduction Act of 1995.\36\
---------------------------------------------------------------------------

    \32\ 5 U.S.C. 553.
    \33\ 5 U.S.C. 553(b).
    \34\ The Commission made a similar finding in 1972 in adopting 
the no-deny policy without notice and comment. See 37 FR 25224 (Nov. 
29, 1972); see also Powell, 149 F.4th at 1046 (holding that the 
Commission acted properly under the APA when it adopted Rule 
202.5(e) without notice and comment).
    \35\ 5 U.S.C. 601(2). 604(a).
    \36\ 5 CFR 1320.3(c).
---------------------------------------------------------------------------

    The Office of Management and Budget (``OMB'') has determined that 
this action is a significant regulatory action under Executive Order 
12866, as amended, and the action has been reviewed by OMB. This action 
is an Executive Order 14192 deregulatory action. For purposes of 
Subtitle E of the Small Business Regulatory Enforcement Fairness Act of 
1996 (also known as the Congressional Review Act),\37\ OMB has 
determined the final rule is not a ``major rule.''
---------------------------------------------------------------------------

    \37\ 5 U.S.C. chapter 8.
---------------------------------------------------------------------------

    The rescission of this policy statement does not impose any new 
rules, regulations, or other requirements on non-agency parties, but it 
could expand the range of possible settlements in Commission 
enforcement actions compared to when the policy was in place. Different 
parties have different goals when approaching possible settlement, and 
it is difficult to estimate how important the ability to deny 
allegations may be to certain parties or whether parties may change 
their approach to settlement negotiations following this rescission. To 
the extent that more parties enter into settlements with the Commission 
as a result of the rescission, those settlements could reduce 
litigation costs for such parties and the Commission and help to 
conserve judicial resources.
    The APA generally requires that an agency publish an adopted 
substantive rule in the Federal Register 30 days before it becomes 
effective.\38\ This requirement, however, does not apply to 
``interpretative rules and statements of policy,'' nor does it apply if 
the agency finds good cause for making the rule effective sooner.\39\ 
For the reasons discussed in section II as to why we are rescinding the 
no-deny policy, and because delaying the effective date could create a 
period of time in which parties have an incentive to delay settlement 
until the rescission is in effect, we find delaying the effective date 
of this rescission is unnecessary and would be contrary to the public 
interest, and thus we find good cause to make the rescission effective 
[upon publication in the Federal Register]. For the same reasons, this 
rescission may take effect [upon publication in the Federal Register] 
pursuant to 5 U.S.C. 808(2).
---------------------------------------------------------------------------

    \38\ 5 U.S.C. 553(d).
    \39\ Id.
---------------------------------------------------------------------------

Statutory Authority

    This release is being adopted pursuant to section 19 of the 
Securities Act of 1933, sections 21 and 23(a) of the Securities 
Exchange Act of 1934, section 38 of the Investment Company Act of 1940, 
and section 211 of the Investment Advisers Act of 1940.

[[Page 29896]]

List of Subjects in 17 CFR Part 202

    Administrative practice and procedure.

    For the reasons set out in the preamble, the Commission is amending 
title 17, chapter II of the Code of Federal Regulations as follows:

PART 202--INFORMAL AND OTHER PROCEDURES

0
1. The authority citation for part 202, continues to read in part as 
follows:

    Authority:  15 U.S.C. 77s, 77t, 77sss, 77uuu, 78d-1, 78u, 78w, 
80a-37, 80a-41, 80b-9, 80b-11, and 7202, unless otherwise noted.
* * * * *


0
2. Amend Sec.  202.5 by removing and reserving paragraph (e).

    By the Commission.

    Dated: May 18, 2026.
Vanessa A. Countryman,
Secretary.
[FR Doc. 2026-10132 Filed 5-20-26; 8:45 am]
BILLING CODE 8011-01-P


</pre></body>
</html>
Indexed from Federal Register on May 21, 2026.

This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.