Patrick M. Mellon

Feb 12, 2024 | lexology.com | Charles Sommers |Andrew Blake |W. Hardy Callcott |Kevin J. Campion |David Katz |Patrick M. Mellon | +2 more

On February 6, 2024, in a 3–2 vote along party lines, the U.S. Securities and Exchange Commission (SEC) adopted rules that further define what constitutes “dealer” or “government securities dealer” activity for purposes of the Securities Exchange Act of 1934 (Exchange Act).1 The adopted rules generally require any person that engages in a regular pattern of buying and selling securities (or government securities) that has the effect of providing liquidity to other market participants to have...