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Exchange-traded funds (ETFs) are a popular investment tool for investors, providing market access to a diverse set of industries and asset classes through a liquid investment strategy. While private credit markets have exploded in popularity and become a favored investment class for many institutional investors over the past 20 years, their illiquid nature and sizable investment requirements make the private credit space generally inaccessible to retail investors. However, a new class of ETFs has recently been introduced to public markets that aims to provide retail investors with new access to the private credit market.

After years of concern over the cost of the consolidated audit trail (CAT), Consolidated Audit Trail, LLC (CAT LLC) proposed a sweeping amendment that could reduce annual CAT operating expenses by as much as $73 million. On December 18, 2025, CAT LLC submitted to the Securities and Exchange Commission (SEC) a proposed amendment to the National Market System Plan Governing the Consolidated Audit Trail (the CAT NMS Plan) designed to materially reduce the ongoing costs of operating the CAT. The proposal (2025 Cost Savings Amendment) reflects a recalibrated approach to cost reduction following extensive industry feedback and prior SEC action.

Katten's 2025 Pro Bono Annual Review, Empowering Better Futures, spotlights our firm's unwavering dedication to empowering individuals and organizations in need through our broad spectrum of pro bono work. This year's report underscores Katten's focus on people, from those facing unsafe circumstances and enduring challenges to changemakers seeking to expand opportunities within their communities, rather than causes alone. This commitment to helping others achieve better futures is reflected in our deeply rooted long-term relationships, with many pro bono opportunities arising from established clients and trusted partnerships.

On December 18, 2025, President Trump signed the annual defense bill, aptly named the National Defense Authorization Act for Fiscal Year 2026 (the NDAA), into law. Buried in the NDAA, beginning on page 2718, congressional lawmakers included the "Holding Foreign Insiders Accountable Act" (the HFIAA). The HFIAA for the first time imposes the reporting obligations under Section 16 of the U.S. Securities Exchange Act of 1934 (the Exchange Act) on directors and officers of Foreign Private Issuers (FPIs), including Canadian companies that satisfy their reporting obligations utilizing the U.S.-Canada Multijurisdictional Disclosure System.

What should a broker-dealer do when a customer's contact information no longer works? The law imposes responsibilities on broker-dealers in such situations. We expect the Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and State securities regulators to have heightened interest and increased scrutiny over "orphaned" accounts, which are those where the designated representative relationship has ended or the client has become unresponsive. Recent SEC and FINRA actions and regulatory priorities focus on retail accounts, underscoring that firms must actively supervise these accounts, make diligent efforts to locate the customer, maintain escalation protocols, avoid charging fees for services not provided, and, if contact remains unsuccessful, transfer the abandoned property to the state. Failure to follow the rules governing orphaned accounts can expose a broker-dealer to significant sanctions.