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Who Needs Customers, Anyway? New SEC Rules Turn Traders Into Dealers

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

SEC Adopts Long-Awaited and Heavily Debated Private Fund Adviser Rules

The U.S. Securities and Exchange Commission ("SEC") adopted multiple rules that will impact private funds, governing documents, and side letters....more

New Law Exempts M&A Brokers from SEC Registration

In Short - The Situation: Congress recently amended the Securities Exchange Act of 1934 (the "Exchange Act") to exempt certain "M&A brokers" from registration as broker-dealers with the U.S. Securities and Exchange...more

SEC Proposes Rules to Clarify Dealer-Trader Distinction

The SEC's Proposal - On March 28, 2022, the SEC released a rulemaking proposal (the "Proposal") for new rules to clarify the meaning of certain terms in the statutory definitions of "dealer" and "government securities...more

SEC's Proposed Rules Target Advisers to Private Funds

On February 9, 2022, the SEC proposed new rules focused on private fund advisers' practices, reporting, and disclosures ("Proposed Rules"). The Proposed Rules would apply to all SEC registered advisers to private funds, and a...more

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