MFA submits supplemental comment letter on dealer proposal

The Managed Funds Association (MFA) has submitted comments to the Securities and Exchange Commission (SEC) regarding the proposed rulemaking to further define the terms “dealer” and “government securities dealer” under the Securities Exchange Act of 1934. MFA expresses concerns about the vagueness and overbreadth of the proposed quantitative and qualitative tests for determining dealer status. MFA believes that material changes are needed, and they are worried that the Commission may finalize these changes without allowing market participants to comment, potentially resulting in a rule that is not appropriately tailored. Additionally, MFA is concerned about the possibility of enforcement actions based on ambiguous and unprecedented theories of dealer status.