In a letter filed today with the Securities and Exchange Commission, the FIA Principal Traders Group (FIA PTG) offered additional comments on the SEC's Definition of a Dealer proposal. FIA PTG said that while it appreciates the importance of the proposal's stated goals to prevent market disruptions and support market transparency, integrity, resiliency, and investor protection, it fails to see how this proposal addresses any of those issues in a meaningful way.
FIA PTG believes the nature of the trading activity is the most important aspect of the dealer definition and this concept is lost in the actual proposal criteria. Any rulemaking aimed at clarifying what is dealing activity should narrowly focus on activity that is well-understood to constitute dealing activity. FIA PTG offered suggested modifications to the proposed criteria and urged the SEC to either modify the proposal to more accurately describe actual dealing activity or to withdraw the proposal completely.
Read the full letter here.