May 20, 2022

Via Electronic Submission

Vanessa A. Countryman Secretary
Securities and Exchange Commission
Washington, D.C. 20549-1090

Re: Request for Extension of Comment Period for File No. S7-12-22

Dear Ms. Countryman:

On behalf of their memberships, the Managed Funds Association (“MFA”), Securities Industry and Financial Markets Association (“SIFMA”), SIFMA Asset Management Group (“SIFMA AMG”), FIA Principal Traders Group (“FIA PTG”), Investment Adviser Association (“IAA”), and Alternative Investment Management Association Limited (“AIMA”) (together, the “Associations”)1 respectfully request that the U.S. Securities and Exchange Commission (“Commission” or “SEC”) extend the comment period for the Commission’s proposal entitled “Further Definition of ‘As a Part of a Regular Business’ in the Definition of Dealer and Government Securities Dealer” (“Proposal”).2 Specifically, we request that the Commission extend the comment period from the current 60-day period following publication of the proposing release on the SEC’s website to a 120-day period from the date of publication in the Federal Register to provide the industry and the public with a more appropriate time period in which to evaluate and comment on the Proposal.

Given the scope of the new requirements proposed and the potential costs that they may impose on participants in the markets, particularly the cash Treasury and Treasury futures markets, the current 60-day period does not afford the public enough time to properly evaluate and provide meaningful feedback on the Proposal. The Associations are eager to work with the Commission and its staff on the important issues addressed in the Proposal, but additional time is needed to understand and consider the impact of the new requirements proposed by the Commission, including assessing the costs of registration and compliance, as well the potential economic impact and systemic risk implications for markets. This is particularly important due to the need for the Associations to prepare comments on several other Commission proposals whose comment periods are still open or were open when the Proposal was issued.

1 See Appendix for descriptions of the Associations.
2 Further Definition of ‘As a Part of a Regular Business’ in the Definition of Dealer and Government Securities Dealer, 87 Fed. Reg. 23,054 (Apr. 18, 2022).