Comments on Further Definition of "As a Part of a Regular Business" in the Definition of Dealer and Government Securities Dealer

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Date Received
Date Letter Type Commenter Name
Public Comment Nathan Barron
Public Comment Eric J. Pan, President & CEO and Susan Olson, General Counsel, Investment Company Institute
Public Comment Brandon Smith
Public Comment Dave Cazza
Public Comment N. Abanes
Public Comment Rebekah Goshorn Jurata, General Counsel, American Investment Council
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding an August 1, 2023 virtual meeting with representatives of Investment Advisers Association
Meeting with SEC Officials Memorandum from the Office Of Commissioner Hester M. Peirce regarding a July 25, 2023 meeting with representatives of the Futures Industry Association
Meeting with SEC Officials Memorandum from the Office of Commissioner Mark T. Uyeda regarding a July 25, 2023 meeting with representatives of the FIA Principal Traders Group
Meeting with SEC Officials Memorandum from the Office of Commissioner Jaime Lizárraga regarding a July 25, 2023 meeting with FIA Principal Traders Group
Public Comment Jennifer W. Han, Executive Vice President, Chief Counsel & Head of Global Regulatory Affairs, Managed Funds Association
Meeting with SEC Officials Memorandum from the Office Of Commissioner Caroline Crenshaw regarding a June 5, 2023 meeting with representatives of SIFMA
Meeting with SEC Officials Memorandum from the Office of Commissioner Hester M. Peirce regarding a May 11, 2023 meeting with Two Sigma
Meeting with SEC Officials Memorandum from the Office Of the Chair regarding a June 26, 2023 meeting with representatives of Investment Adviser Association
Meeting with SEC Officials Memorandum from the Office of Commissioner Hester M. Peirce regarding a January 18, 2023 meeting with representatives of Element Capital
Meeting with SEC Officials Memorandum from the Office of Commissioner Hester M. Peirce regarding a March 16, 2023 meeting with representatives of JP Morgan
Public Comment Ben Passlow
Meeting with SEC Officials Memorandum from the Office of Commissioner Jaime Lizárraga regarding an April 25, 2023 meeting with representatives of the Alternative Investment Management Association
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding an April 20, 2023 meeting with BlackRock, Inc.
Meeting with SEC Officials Memorandum from the Office of Commissioner Uyeda regarding an April 18, 2023, meeting with representatives of the Alternative Investment Management Associate
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding an April 13, 2023 virtual meeting with representatives of the Managed Funds Association
Public Comment Jennifer W. Han, Managed Funds Association
Public Comment Matthew B. Siano, Esq., Managing Director, General Counsel, Two Sigma
Meeting with SEC Officials Memorandum from the Office of Public Engagement regarding a March 22, 2023 meeting with Financial Services Forum
Public Comment Samantha DeZur, Managing Director, Global Public Policy, Michael Winnike, Director, Market Structure, Global Trading, and Waqaas Fahmawi, Director and Counsel, Trading & Derivatives, BlackRock, Inc.
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a March 8, 2023 virtual meeting with Sidley Austin LLP
Meeting with SEC Officials Memorandum from the Office of Commissioner Mark T. Uyeda regarding a February 10, 2023 meeting with representatives of Element Capital Management
Public Comment United States Senator Bill Hagerty and U.S. Representative French Hill
Meeting with SEC Officials Memorandum from the Division of Economic and Risk Analysis regarding a January 13, 2023 meeting with Element Capital Management, LLC
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a January 25, 2023 virtual meeting with a representative of the Managed Funds Association

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-12-22
Release Number
34-94524
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