Today, the SPCC filed comments on the SEC’s proposed “dealer” definition.
The SEC’s enforcement activity threatens to throw the broader securities market into disarray. The commission’s enforcement theory calls into question the legality of most of modern American finance, as a large proportion of firms that trade securities—including as their sole business activity, such as hedge funds—are not, and have never been, registered as “dealers.”
Already, the commission’s enforcement activity has caused enormous hardship for the SPCC’s members. The SPCC is the voice of small public companies—firms that employ thousands of Americans developing new and innovative products and services. The Coalition’s mission is to protect this industry, and the financial professionals who serve it, from harmful government interference that suppresses growth, hinders capital formation, and eliminates jobs. Unfortunately, the Commission’s enforcement staff has wielded its expansive conception of “dealing” in an attempt to eliminate a vital source of financing for small public companies: market adjustable convertible securities.
The SPCC will continue to work on this issue and abate burdensome enforcement activity from the commission.
Contact:
info@thespcc.com