Firm News
SRZ Submits Comment Letter on the SEC's Proposed Rules to Revise and Expand the Definitions of 'Dealer' and 'Government Securities Dealer'
June 8, 2022
SRZ submitted comments to the U.S. Securities and Exchange Commission (“SEC”) on the agency’s proposed rules to revise and expand the definitions of “dealer” and “government securities dealer” under Sections 3(a)(5) and 3(a)(44) of the Securities Exchange Act of 1934. Because of the substantial impact the rules would have on private funds – i.e., by treating common trading strategies as dealer activity and requiring that many funds and advisers either register as a dealer or cease such trading activity – SRZ urged the SEC to undertake a study of the impact of the rules and its unintended consequences before making such a significant change.
SRZ is carefully following the development of new rules affecting private investment fund managers and invites continued dialogue on these matters.
Related Insights
Alerts
The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]
Alerts
The US Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) have overhauled Form PF and private fund managers have until March 12, 2025, to begin reporting on the new Form. The changes to the reporting requirements mandated by the amendments to the Form (“Form PF Amendments”) will require substantial preparation by many managers.[1]