Is the SEC’s Expansion of the “Exchange” and “Dealer” Definitions Part of the Agency’s Crypto and DeFi Strategy?

In March 2022, the U.S. Securities and Exchange Commission proposed rules that would greatly expand the Exchange Act definition of “dealer” and essentially kill the distinction between dealers and traders long-recognized by the SEC. The likely outcome is that most proprietary trading firms will need to register with the SEC as dealers and become members of FINRA or a national securities exchange. Goodwin’s Nick Losurdo and Chris Grobbel share more on this update in a recent client alert. Read more here.