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 Joseph P. Corcoran and Rob Toomey, Managing Directors and Associate General Counsels, Securities Industry and Financial Markets Association
Public Comment Kirsten Wegner, Chief Executive Officer, Modern Markets Initiative
Public Comment Matthew B. Siano, Esq., Managing Director, General Counsel, Two Sigma
Public Comment Michelle Bond, CEO, Association for Digital Asset Markets
Public Comment National Association of Private Fund Managers
Public Comment Partners of AlphaWorks Capital Management, LLC
Public Comment Patrick C. Reeder, Vice President & Deputy General Counsel, American Council of Life Insurers
Public Comment Sarah A. Bessin, Associate General Counsel, Investment Company Institute, Associate General Counsel, Investment Company Institute; Nhan Nguyen, Assistant General Counsel, Investment Company Institute
Public Comment Schulte Roth & Zabel LLP
Public Comment Small Public Company Coalition
Public Comment Virtu Financial, Inc.
Public Comment William C. Thum, SIFMA Asset Management Group, SIFMA AMG
Public Comment Julian Gretzinger, General Manager,Gretz Consilium LLC
Meeting with SEC Officials Memorandum from the Division of Investment Management regarding a May 26, 2022 Virtual Meeting with Representatives from BlackRock
Public Comment William C. Hughes, Senior Counsel & Director of Global Regulatory Matters, Consensys Software Inc.
Public Comment McIntyre & Lemon, PLLC
Public Comment Jennifer W. Han, Managed Funds Association
Public Comment Blockchain Association
Public Comment Jiri Krol, Deputy CEO, Global Head of Government Affairs, AIMA
Meeting with SEC Officials Memorandum from the Office of the Chair regarding an April 15, 2022 meeting with a representative of Delta Strategy Group
Meeting with SEC Officials Memorandum from the Office of the Chair regarding an April 15, 2022 meeting with representatives of Delta Strategy Group
Public Comment Adelle Nazarian, CEO, and Todd A. White, Founder, American Blockchain PAC
Public Comment U.S. Representatives Patrick McHenry and Bill Huizenga
Public Comment Amad Zarak
Public Comment Nicolas Zach, Student (IT)
Public Comment Andrew Robison, Individual Investor
Public Comment John Thomas, Retired
Public Comment Adam Beherns, Engineer
Public Comment David E., Retail Investor
Public Comment Denys Petrina

Last Reviewed or Updated: Dec. 18, 2025

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