At the SEC Speaks in 2026, a panel of attorneys from the SEC Office of the General Counsel, moderated by Deputy GC Jeffrey Finnell, offered views from the trenches on recent litigation with potentially significant consequences for the agency’s authority and market participants. Most notable are two matters now before the U.S. Supreme Court. One involves the circumstances under which the SEC can require disgorgement of ill-gotten gains. The other concerns whether there is a private right of action to rescind contracts that violate the Investment Company Act of 1940. There are also, however, matters that have been decided by, or are pending in, the U.S. Courts of Appeals that also have a bearing on future Commission authority and practices. Among the relevant matters are those aimed at determining what constitutes a final agency decision under the Administrative Procedure Act and the ability of a respondent to reopen an SEC settlement. This article synthesizes the SEC attorneys’ insights. See “Division of Investment Management Staff Discuss Staffing, Operations, Rulemaking and Other Developments” (Oct. 16, 2025).