Project 2025 Tracker / What’s done, what’s next

Section 5 · Independent Regulatory Agencies

27 Financial Regulatory Agencies

  • 9 partially done
  • 16 attempted
  • 1 blocked
  • 34 not started

Major recommendations (6)

What has happened

The Mandate said

“Provided the Supreme Court affirms the Fifth Circuit holding in Community Financial Services Association of America, the next conservative President should order the immediate dissolution of the agency—pull down its prior rules, regulations and guidance, return its staff to their prior agencies and its building to the General Services Administration.”

What happened

Blocked

The en banc court denied the government's motion to modify the stay, held the appeal in abeyance while retaining jurisdiction, and remanded for the district court to decide in the first instance whether to modify, suspend or dissolve the injunction in light of a revised reduction-in-force plan. The injunction remains in force in the meantime. The Bureau is still standing and still issuing rules: it published a regulatory agenda on 2026-08-14 and a joint rescission notice on 2026-08-25.

The Mandate said

“Prohibit the SEC from requiring issuer disclosure of social, ideological, political, or “human capital” information that is not material to investors’ financial, economic, or pecuniary risks or returns. The proposed SEC climate change rule, which would quadruple the costs of being a public company, is particularly problematic.”

What happened

Attempted

The SEC proposed to rescind the climate-related disclosure rules — the rule the Mandate singles out — repealing the Securities Act and Exchange Act amendments that require registrants to provide climate information in registration statements and annual reports. Re-checked on 2026-09-06: it is still a proposal. A Federal Register API search of every SEC document published since 2026-01-01 for "climate-related disclosure" returns three, of which this is the only rulemaking on the rescission; no final rescission has been published, the climate rules are still on the books, and Congress has enacted nothing barring the SEC from requiring non-material disclosure.

The Mandate said

“The SEC and Congress should fundamentally reform the securities laws governing issuers, broker–dealers, exchanges, and other market participants. Among other things, they should establish a simplified and rationalized securities disclosure system with: … Three basic categories of firm: private firms, an intermediate category of smaller firms, and public firms; Reasonable, scaled disclosure requirements; and Specified secondary markets for the securities of these firms.”

What happened

Attempted

The SEC opened a scaled-disclosure rewrite in May 2026, by proposal rather than by rule. The central proposal would collapse Exchange Act filer statuses into two primary categories — large accelerated and non-accelerated — raise the threshold and seasoning requirements for large accelerated status, and extend the accommodations and scaled disclosures now reserved for smaller reporting companies and emerging growth companies to every non-accelerated filer. Alongside it the Commission proposed letting companies report semiannually on a new Form 10-S instead of quarterly (2026-05-07) and a registered-offering reform opening Form S-3 and shelf offerings to far more issuers while preempting state registration for all registered offerings (2026-05-26). None of the three is final; the Mandate's three-category structure and its "specified secondary markets" are not what is proposed; and Congress has not touched the Securities Act or the Exchange Act.

The Mandate said

“Offices at financial regulators that promote racist policies (usually in the name of “diversity, equity, and inclusion”) should be abolished, and regulations that require appointments on the basis of race, ethnicity, sex, or sexual orientation should be eliminated.”

What happened

Attempted

The SEC's implementation of the directive is now on the record, and it stops short of the ask. GAO's triennial personnel-management report finds that the Commission "updated certain personnel management policies and procedures to remove references to diversity, equity, and inclusion" — in April 2025 removing all references to diversity from its candidate-interview questions and a reference to hiring panels considering diverse perspectives, and in March 2025 removing its strategic-plan goal on diversity, equity and inclusion. Those are internal policies and procedures, not the appointment *regulations* the Quote's second half names (that half is #2128), and none of them abolishes an office. On the office itself the report is explicit and runs the other way: "As of December 2025, SEC's Office of Minority and Women Inclusion had one fully staffed employee, according to SEC officials" — reduced, not abolished. The Commission's own Division and Office Directors page, read on 2026-09-06, still names a Director of the Office of Minority and Women Inclusion. So the government-wide directive has produced documented action at a financial regulator on the subject of the ask, and no financial regulator's DEI office has been abolished: the Fed's and the OCC's statutory Offices of Minority and Women Inclusion under Dodd-Frank section 342 are standing too. The rung does not move.

The Mandate said

“Provided the Supreme Court affirms the Fifth Circuit holding in Community Financial Services Association of America, the next conservative President should order the immediate dissolution of the agency—pull down its prior rules, regulations and guidance, return its staff to their prior agencies and its building to the General Services Administration.”

What happened

Blocked

The D.C. Circuit granted rehearing en banc, vacated the panel's 2025-08-15 judgment, and put the preliminary injunction back in force — as partially stayed on 2025-04-11 and modified on 2025-04-28 — pending argument on 2026-02-24.

Still to come

Executive action 20

  1. Printed page 830 Streamline Regulation A and Regulation CF and preempt blue sky rules for Reg A Notable Not started
  2. Printed page 831 Exempt peer-to-peer lending from federal and state securities laws Notable Not started
  3. Printed page 831 Abolish Rule 144 and other restrictions on securities resales Notable Not started
  4. Printed page 833 Eliminate SEC administrative proceedings except registration stop orders Notable Not started
  5. Printed page 834 Replace the CFTC position limits rule with delegation to exchanges Notable Not started
  6. Printed page 836 Send all SRO fines to a new investor reimbursement fund or the Treasury Notable Not started
  7. Printed page 831 Exempt small micro-offerings from registration requirements Minor Not started
  8. Printed page 832 Publish an annual SEC data book on offerings, markets, and enforcement Minor Not started
  9. Printed page 832 Shift SEC resources from ancillary functions to its core statutory mission Minor Not started
  10. Printed page 832 Empower any three SEC Commissioners to place an item on the agenda Minor Not started
  11. Printed page 833 Cut the number of direct reports to the SEC Chairman Minor Not started
  12. Printed page 834 Shift CFTC resources to core agency functions Minor Not started
  13. Printed page 834 Apply the 2020 Cross-Border Rule definitions to requirements under the 2013 Guidance Minor Not started
  14. Printed page 834 Remove the 'affiliate conduit' and 'foreign consolidated subsidiary' categories Minor Not started
  15. Printed page 835 Open FINRA board meetings, agendas, minutes, and rulemakings to the public Minor Not started

and 5 more →

All recommendations in this chapter

Every recommendation this chapter is the home of, in printed-page order.

  1. Printed page 829 Fundamentally reform the securities laws and create a scaled disclosure system Needs Congress Attempted
  2. Printed page 830 Abolish the PCAOB and FINRA and merge their functions into the SEC Needs Congress Attempted
  3. Printed page 830 Create an independent commission to report on moving SRO functions to the SEC Needs Congress Not started
  4. Printed page 830 Abolish DEI offices at financial regulators Attempted
  5. Printed page 830 Eliminate regulations requiring appointments based on race, sex, or orientation Partially done
  6. Printed page 830 Use the SEC's general exemptive authority far more often Partially done
  7. Printed page 830 Streamline Regulation A and Regulation CF and preempt blue sky rules for Reg A Not started
  8. Printed page 831 Broaden or eliminate the accredited investor restriction under Regulation D Attempted
  9. Printed page 831 Allow self-certification of accredited investor status in Rule 506 offerings Partially done
  10. Printed page 831 Exempt small micro-offerings from registration requirements Not started
  11. Printed page 831 Exempt small finders from broker-dealer registration Partially done
  12. Printed page 831 Exempt peer-to-peer lending from federal and state securities laws Not started
  13. Printed page 831 Make the Title I Emerging Growth Company exemptions permanent Attempted
  14. Printed page 831 Exempt non-custodial broker-dealers from PCAOB-registered audit requirements Partially done
  15. Printed page 831 Exempt crowdfunding shareholders from the S corp 100-shareholder limit Needs Congress Not started
  16. Printed page 831 Preempt state blue sky rules for securities traded on established markets Attempted
  17. Printed page 831 Terminate the Consolidated Audit Trail program Attempted
  18. Printed page 831 Abolish Rule 144 and other restrictions on securities resales Not started
  19. Printed page 832 Bar the SEC from requiring non-material social or political disclosures Needs Congress Attempted
  20. Printed page 832 Repeal Dodd-Frank conflict minerals, mine safety, and pay ratio disclosures Needs Congress Attempted
  21. Printed page 832 Prohibit securities regulators and SROs from race- or sex-based rulemaking Needs Congress Not started
  22. Printed page 832 Publish an annual SEC data book on offerings, markets, and enforcement Not started
  23. Printed page 832 Shift SEC resources from ancillary functions to its core statutory mission Not started
  24. Printed page 832 Empower any three SEC Commissioners to place an item on the agenda Not started
  25. Printed page 833 Eliminate SEC administrative proceedings except registration stop orders Not started
  26. Printed page 833 End delegation of the decision to initiate SEC enforcement cases Partially done
  27. Printed page 833 Require an Inspector General report on SEC IT spending and contracting Needs Congress Not started
  28. Printed page 833 Statutorily cap SEC investigations at two years Needs Congress Not started
  29. Printed page 833 Cut the number of direct reports to the SEC Chairman Not started
  30. Printed page 833 Merge SEC offices performing similar functions Partially done
  31. Printed page 833 Reduce the number of SEC managers per employee Partially done
  32. Printed page 833 Modernize the statutory definition of commodity and clarify digital assets Needs Congress Attempted
  33. Printed page 833 Amend the Commodity Exchange Act to clarify foreign swap platform registration Needs Congress Not started
  34. Printed page 834 Let the CFTC Chairman remove the Executive Director without a Commission vote Needs Congress Not started
  35. Printed page 834 Set CFTC Commissioners' office funding by statute Needs Congress Not started
  36. Printed page 834 Shift CFTC resources to core agency functions Not started
  37. Printed page 834 Replace the CFTC position limits rule with delegation to exchanges Not started
  38. Printed page 834 Pare back prescriptive rules implementing the CFTC's core principles Attempted
  39. Printed page 834 Apply the 2020 Cross-Border Rule definitions to requirements under the 2013 Guidance Not started
  40. Printed page 834 Remove the 'affiliate conduit' and 'foreign consolidated subsidiary' categories Not started
  41. Printed page 835 Issue a joint SEC-CFTC rule defining when a digital asset is a security Partially done
  42. Printed page 835 Amend the definitions of commodity and security to cover digital assets Attempted
  43. Printed page 835 Legislate digital asset classification if regulators fail to act Needs Congress Attempted
  44. Printed page 835 Open FINRA board meetings, agendas, minutes, and rulemakings to the public Not started
  45. Printed page 836 Open FINRA arbitration and disciplinary hearings to the public Not started
  46. Printed page 836 Require FINRA arbitrators to issue reasoned, reviewable decisions Not started
  47. Printed page 836 Send all SRO fines to a new investor reimbursement fund or the Treasury Not started
  48. Printed page 836 Require SROs to conduct cost-benefit analysis on major rules Not started
  49. Printed page 836 Require SROs to publish proposed rules for public comment Not started
  50. Printed page 836 Require each SRO to file a detailed annual report to Congress Not started
  51. Printed page 836 Hold annual congressional oversight hearings on SROs Needs Congress Not started
  52. Printed page 836 Establish an inspector general over FINRA, the MSRB, and the NFA Needs Congress Not started
  53. Printed page 837 Require an annual SEC and CFTC report on SRO supervision Needs Congress Not started
  54. Printed page 839 Abolish the Consumer Financial Protection Bureau Needs Congress Not started
  55. Printed page 839 Order the immediate dissolution of the CFPB Blocked
  56. Printed page 839 Send unused CFPB civil penalty funds to the Treasury Needs Congress Attempted
  57. Printed page 839 Repeal Dodd-Frank Section 1071 small-business data collection Needs Congress Attempted
  58. Printed page 839 Bar CFPB enforcement not grounded in APA-compliant rulemaking Needs Congress Attempted
  59. Printed page 839 Let CFPB respondents elect an Article III court over an administrative one Needs Congress Not started
  60. Printed page 839 Statutorily define 'deceptive, unfair, and abusive' practices Needs Congress Not started