
The SEC’s dismissal of recent “unregistered dealer” enforcement actions cements a scaling back of the dealer definition and reflects a policy shift from the prior SEC.
By Zachary Fallon, John J. Sikora Jr., Stephen P. Wink, Naim Culhaci, Donald Thompson, and Deric Behar
On May 22, 2025, the Securities and Exchange Commission (Commission or SEC) announced that it filed stipulations to completely dismiss with prejudice three civil enforcement actions in which the SEC’s sole claim