SEC Proposed Rescission of Rule 206(4)-5 Published in Federal Register; Comments Due November 9, 2026

Skadden Publication / Political Law Compliance and Investigations Update

Ki P. Hong Charles M. Ricciardelli Tyler Rosen Matthew Bobys Theodore R. Grodek Melissa L. Miles Sam Rothbloom Mason Eiss Jessica Grubesic Kirin Gupta Lucy Kalar Pavla Ovtchinnikova

The SEC’s proposed rescission of Rule 206(4)-5 and related record-keeping requirements, which we described in a prior client alert, was published in the Federal Register on Thursday, September 10, 2026. As a result, the 60-day period for public comment has begun, and comments are due on November 9, 2026.

If you have any questions about submitting a comment, please contact us.

This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.

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