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
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a July 18, 2022 meeting with representatives of Managed Funds Association
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a July 18, 2022 videoconference with representatives of the Modern Markets Initiative
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a July 15, 2022 meeting with representatives of Managed Funds Association
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a July 14, 2022 meeting with representatives of Principal Traders Group
Meeting with SEC Officials Memorandum from the Division of Trading and Markets regarding a June 29, 2022 virtual meeting with representatives of Modern Markets Initiative
Public Comment Marcia E. Asquith, Financial Industry Regulatory Authority, Inc.
Public Comment Chamber of Digital Commerce
Meeting with SEC Officials Memorandum from Division of Trading and Markets regarding a June 7, 2022 a virtual meeting with representatives of Modern Markets Initiative.
Public Comment Morgan, Lewis & Bockius LLP
Public Comment T. Rowe Price, T. Rowe Price
Meeting with SEC Officials Memorandum from the Office of Commissioner Lee regarding a June 6, 2022 Meeting with Representatives from the Managed Funds Association.
Meeting with SEC Officials Memorandum from the Office of the Chair regarding a June 7, 2022 meeting with MarketAxess and Brownstein Farber Hyatt Schreck
Public Comment Stephen John Berger, Managing Director, Global Head of Government and Regulatory Policy, Citadel
Public Comment Investment Adviser Association
Public Comment McIntyre & Lemon, PLLC
Public Comment Element Capital Management LLC
Public Comment Andreessen Horowitz
Public Comment Better Markets
Public Comment Blockchain Association
Public Comment DeFi Education Fund
Public Comment Fried, Frank, Harris, Shriver & Jacobson LLP
Public Comment Global Digital Asset and Cryptocurrency Association - Gabriella Kusz, CEO, Global Digital Asset and Cryptocurrency Association
Public Comment Hedge Fund Association
Public Comment James A. Overdahl, Ph.D., Partner, Delta Strategy Group
Public Comment James Tabacchi, Chairman, Independent Dealer and Trader Association (IDTA)
Public Comment Jay Knight, Chair of the Committee on Federal Regulation of Securities of the Section of Business Law of the American Bar Association
Public Comment Jennifer W. Han, Managed Funds Association
Public Comment Jiri Krol, Deputy CEO, Global Head of Government Affairs, AIMA
Public Comment Joanna Mallers, Secretary, FIA Principal Traders Group
Public Comment Joseph P. Corcoran and Rob Toomey, Managing Directors and Associate General Counsels, Securities Industry and Financial Markets Association

Last Reviewed or Updated: Dec. 18, 2025

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