SabalLaw Week in Review: September 26–October 2, 2025
Catch up on this week’s key legal and regulatory updates impacting startups, funds, and emerging tech. @SabalLaw breaks it down:
The SEC issued a no-action letter on September 30, 2025, allowing DoubleZero’s DePIN token (2Z) to launch without securities registration, signaling a lighter regulatory approach for blockchain-based infrastructure projects.
The SEC’s Division of Investment Management issued a no-action letter on September 30, 2025, permitting state trust companies to act as custodians for crypto assets, subject to state authorization, expanding opportunities for digital asset custody.
The SEC and CFTC announced on September 29, 2025, plans to harmonize regulations, reduce duplicative rules, and coordinate on digital asset rulemaking, aiming to clarify jurisdiction and foster market innovation.
The SEC approved the Texas Stock Exchange’s registration on September 30, 2025, enabling it to launch trading in exchange-traded products and stocks in 2026, offering a new venue for securities markets.
The SEC received a petition on September 30, 2025, from the Long-Term Stock Exchange to allow public companies to report earnings semiannually, aiming to reduce short-term pressures while maintaining transparency.
FinCEN requested comments by December 1, 2025, on a proposed survey to assess AML/CFT compliance costs for non-bank financial institutions, supporting potential deregulation efforts.
The SEC held its first webinar on September 25, 2025, to guide firms on Regulation S-P amendments, emphasizing incident response programs and third-party oversight for customer data protection, with compliance due by December 3, 2025.
Avenue Capital Group closed its $1 billion Sports Fund on September 29, 2025, investing in sports teams, leagues, and adjacent businesses, including the Baltimore Orioles and TGL’s Bay Golf Club.
Polymarket plans to relaunch in the U.S. on October 2, 2025, after acquiring a CFTC-licensed exchange, enabling it to offer sports and election event contracts to U.S. users.
A California federal judge ruled on October 2, 2025, that Bored Ape NFTs are not securities under the Howey test, dismissing a class action but allowing plaintiffs to amend their complaint by October 10, 2025.
Regulators including the SEC and FINRA began probing unusual trading activity on September 26, 2025, ahead of corporate crypto-treasury announcements, raising concerns over potential insider trading and Regulation Fair Disclosure violations.
The SEC issued guidance on September 30, 2025, for operations during the government shutdown starting October 1, 2025, confirming EDGAR filings continue but staff reviews are paused, with business days still counting toward deadlines.
The White House withdrew Brian Quintenz's nomination to chair the CFTC on September 30, 2025, following opposition from Gemini co-founders Tyler and Cameron Winklevoss over his refusal to assure favorable handling of their regulatory dispute.
U.S. Secretary of Commerce Howard Lutnick announced on September 30, 2025, that registration opened for the 2026 SelectUSA Investment Summit, set for May 3–6, 2026, in National Harbor, MD, to promote foreign direct investment and connect international investors with U.S. economic developers.
The Big Ten Conference discussed a $2 billion private capital deal on September 26, 2025, including a 10-year grant-of-rights extension to 2046, to create a new revenue entity (Big Ten Enterprises) and provide upfront nine-figure payments to each school.
The CFTC issued Advisory Letter 25-36 on September 30, 2025, cautioning futures commission merchants, exchanges, and clearing organizations to prepare contingency plans for sports-related event contracts amid state regulatory actions and litigation risks.
The SEC released a concept release on September 26, 2025, seeking public comments on revising RMBS rules, including asset-level disclosures, to revive the dormant private-label market, which has seen no registered offerings since June 2013.
ICYMI:
The SEC’s Investor Advisory Committee recommended on September 18, 2025, modernizing accredited investor rules to focus on financial sophistication, not wealth, to expand retail access to private markets.
The president’s Working Group on Digital Asset Markets released a report on July 30, 2025, urging regulators to clarify permissible digital asset activities for banks, including custody and stablecoin reserves.
The New England Patriots sold an 8% stake at a $9 billion valuation to Sixth Street and Dean Metropoulos, reflecting growing private investment in sports franchises.
The San Francisco 49ers sold a 3.2% stake to Pete Briger Jr. at an $8.5–8.6 billion valuation, with the York family retaining majority control.
Mark Ein acquired a minority stake in the Baltimore Orioles joining the David Rubenstein-led ownership group; the team was valued at $1.7 billion when purchased last year, adding to Ein's sports portfolio including the Washington Commanders and Leeds United.
Red Bull Ventures invested in Apex Capital’s Elite Performance Fund on September 24, 2025, supporting early-stage sports tech startups like TMRW Sports, with over 100 athletes from 17 sports backing the fund.
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