Revitalizing America’s Markets on its 250th Birthday

On December 2, 2025, SEC Chairman Paul Atkins stood on the floor of the New York Stock Exchange and used America’s upcoming 250th birthday to pose a simple but uncomfortable question: have our capital markets drifted too far from their original purpose?

His answer was equally simple: yes—and it is time to reset.

For broker-dealers, investment advisers, and compliance professionals, this is more than a patriotic speech. It is an early roadmap of how the SEC under Atkins may reshape disclosure, IPOs, and litigation risk in the years ahead. Understanding that roadmap now can help firms align their governance, procedures, and technology before the rule proposals start landing in the Federal Register.

The reality, according to Atkins, is that over the decades disclosure rules have expanded far beyond what is financially material. The SEC’s rulebook has become “regulatory creep” in action: more pages, more checklists, more social and political mandates, but not necessarily better information for investors. He points to a stark data point: in the mid-1990s, there were more than 7,000 listed companies in the U.S. Today that number has fallen by roughly 40%, with many growth companies staying private longer or heading overseas. For firms, especially smaller public companies and would-be IPO candidates, that trend translates into higher compliance costs, reduced access to public capital, and fewer opportunities for everyday investors.

Atkins’ Three Big Themes for Reform

Re-centering disclosure on materiality

Atkins wants the SEC’s disclosure regime to return to an objective standard: information is material if a reasonable shareholder would consider it important to an investment decision.

He warns that forcing issuers to disclose too much low-value information creates an “avalanche” that buries investors, a concern echoed by the Supreme Court and by Warren Buffett’s recent Thanksgiving letter, which criticized executive pay disclosures that ballooned proxy statements without producing better governance.

Scaling obligations to company size and maturity
Atkins specifically calls out the problem of smaller issuers being treated like mega-caps. In some cases, a company with $250 million in public float is subject to essentially the same disclosure complexity as a firm 100 times its size.

He suggests revisiting and expanding concepts like:

• Tiered disclosure thresholds for “smaller reporting companies”; and

• A more durable “IPO on-ramp” (building on the JOBS Act) that gives emerging issuers a multi-year glidepath to full compliance, not just a one-year honeymoon.

Making IPOs “great again” and de-politicizing governance

Atkins frames his plan as a three-pillar effort to “make IPOs great again”:

• Reform disclosure to be materiality-driven and scaled;

• De-politicize shareholder meetings to focus on director elections and core corporate questions rather than broader social battles; and

• Reform the securities litigation landscape to deter frivolous suits while preserving valid investor claims.

Why This Matters for Broker-Dealers and RIAs

Even before formal rules change, a speech like this shifts expectations. Enforcement, exams, and staff guidance often begin to reflect the Chair’s philosophy long before the ink dries on new regulations.

Some implications we’re watching closely at GiGCXOs:

Issuer and fund disclosure strategy
Public companies, funds, and their underwriters may feel emboldened to push back on disclosure demands that are weakly tied to materiality. Expect sharper debates in S-1s, N-1As, and offering documents about what truly belongs in the filing versus what is better addressed via voluntary reporting or stewardship communications.

Compliance program calibration
For broker-dealers and advisers, WSPs and compliance manuals that simply “mirror” every new disclosure or ESG trend may start to look out of step. Examiners will still expect robust controls, but they may place greater emphasis on:

• How your disclosures tie to financial risks and investor decision-making; and

• Whether your policies and procedures scale appropriately with firm size and complexity rather than mindlessly duplicating mega-cap practices.

IPO and capital-formation pipelines
If the SEC follows through with expanded IPO on-ramp concepts and more generous small-issuer thresholds, the cost-benefit calculus of going public could shift, especially for growth companies weighing a U.S. listing versus staying private or going abroad.

Firms that are ready with clean books and records, sensible governance, and scalable compliance infrastructure will be better positioned to take advantage of any “IPO revival.”

Atkins closed his speech by framing capital markets as an expression of American character: risk-taking, innovation, and individual agency. The open question, he said, is not whether entrepreneurs can reinvigorate the markets, but whether regulators have the will to let them.

Firms don’t have to wait for the answer. By aligning your disclosure, governance, and compliance program with a materiality-first, scaled-to-risk philosophy today, you can be ready for whatever comes next, while protecting your investors and your business.

If your firm wants a practical assessment of how this emerging SEC agenda might affect your current program, GiGCXOs can help you build that roadmap.