The SEC’s dismissal of recent “unregistered dealer” enforcement actions cements a scaling back of the dealer definition and reflects a policy shift from the prior SEC....more
On February 6, 2024, the Securities and Exchange Commission (SEC) adopted Rules 3a5-4 and 3a44-2 under the Securities Exchange Act of 1934 (Exchange Act), which significantly expand the definitions of “dealer” and “government...more
The Securities and Exchange Commission (the "SEC" or "Commission") has adopted new rules that further define the phrase "part of a regular business" for purposes of determining whether a person is a "dealer" or "government...more